Privacy Policy

We at Bazk strive to maintain a relationship of trust and transparency with everyone we interact with and who accesses our website and/or application ("Platform(s)"), such as our prospects, clients, business partners, and candidates for job openings ("you"). For this reason, we guarantee that your browsing on https://www.bazk.com/ and on our platforms will be done with the utmost security, in compliance with current privacy standards, as well as throughout your relationship with us. This is because, for us, the priority is to protect the privacy and security of your personal data. Therefore, any information you provide to us will be handled in accordance with the limits set forth here and in accordance with applicable laws. For this reason, we have prepared this Privacy Notice ("Notice") to help you understand how your information is processed by Bazk and how you can exercise your rights related to this information.

We inform you that we do not intend to collect or process personal data from individuals under the age of 18, as the website and platforms are intended only for adults. Therefore, if we become aware that we have collected personal data from an individual under 18, we will disregard the information provided and will not retain it in our databases.

If you have any questions related to the protection of your personal data and/or this Privacy Notice, we have made an appropriate contact channel available for clarification at dpo@bazk.com. Please feel free to contact us.

1. Summary of Key Information

To make this Notice easier to understand, we have provided a summary of the key information that will be presented to you in this document:

WHAT DATA WILL BE PROCESSED?

Below is a brief list of some of the personal data we process, which will be detailed in Section 3:

  • Personal data: name, date of birth, ID, CPF, profession, company or institution you work for, position, workplace, address, phone, email, bank account and branch, PIX key, consumer or professional profile, social media usage patterns, attributes associated with your electronic devices and cookies, company or institution, service protocol numbers.

  • Sensitive personal data: data related to your health or political affiliation and classification as PEP (Politically Exposed Person), biometrics. In cases of complaints or reports to our ombudsman, data regarding racial or ethnic origin, sexual orientation, and religious beliefs may also be processed.

WHY DO WE NEED YOUR PERSONAL DATA?

Below are some of the purposes for which we process your personal data, as detailed in Section 4:

  • To provide our services or execute a contract you have entered into with us;
  • To fulfill our legal or regulatory obligations;
  • To enable the regular exercise of our rights;
  • To prevent fraud and ensure your security;
  • To conduct advertising activities and communicate with you;
  • To carry out our recruitment and selection activities;
  • To facilitate activities necessary for Bazk.

WHEN MIGHT YOUR PERSONAL DATA BE SHARED?

We may share your personal data with third parties to achieve the purposes for which it was collected. There may also be sharing when necessary to comply with judicial requests or to fulfill legal or regulatory obligations, as outlined in Section 6.

HOW LONG WILL YOUR PERSONAL DATA BE KEPT?

We store your personal data for as long as necessary to achieve the purposes for which it was collected. When possible, we will keep personal data in an anonymized form, respecting the highest levels of care and market security, as outlined in Section 7 of this Notice.

HOW TO EXERCISE YOUR RIGHTS AS A DATA SUBJECT?

We are committed to upholding all your rights as a data subject. For this reason, we have a communication channel to address any questions, suggestions, or requests related to the processing of the collected personal data. You can contact our Data Protection Officer, Brenda Londero Madeira, at dpo@bazk.com.

2. How do we collect your personal data?

The information we process about you may have been provided directly by you to Bazk, through third-party websites, or even collected automatically through our website and other channels. Let's better understand each of these data collection situations:

  • Information provided directly by you – from the moment you begin interacting with us, you voluntarily provide us with your data, such as, but not limited to, the following situations:
  • When you provide data during the signing of a contract with us;
  • When you engage with our advertisements and stands at trade fairs;
  • When you send a message to our Ethics Channel or Ombudsman;
  • When you submit a ticket to our support team;
  • When you register on our website and access your account;
  • When you send your resume to participate in our recruitment processes;
  • When you fill out our online form to contact our commercial team, or contact us by phone or other means (e.g., WhatsApp, social media, etc.).
  • Information obtained from third parties – In specific cases, we may also receive some of your personal data through third parties. For example, information obtained from our service providers, suppliers, and other partners who help us offer better products and services to you; information from third-party websites and paid media; data provided directly by our clients or partner banks, betting operators, or credit bureaus, as well as information shared by companies within our group.
  • Information collected automatically – When you use our services on the website (browsing), including through cookies, as indicated in Section 5.
  • Publicly available information – We may also collect information that is publicly available and found on social media (such as LinkedIn) or in public databases from government agencies (e.g., PROCON, Courts of Justice, Federal Revenue, etc.).

3. What personal data do we process?

In order to respect your privacy, we believe that any processing of personal data should be limited to the minimum necessary, in a relevant and proportional manner, to achieve the intended purpose.

Therefore, the personal data we collect about you will vary depending on the relationship you have with us, whether as a customer or legal/commercial representative, website visitor, lead, partner, job applicant, among others.

Below, grouped into categories, we present the main personal data that may be processed by us:

  • Registration and qualification data – Name; CNPJ; CPF; RG; CNH; nationality; parentage; signature; marital status; date of birth; gender; age; username; photos (selfies for transaction validation);
  • Contact data – Address (street, city, state, country, ZIP code); email and phone (landline and mobile); social media profile; messaging app user;
  • Financial and banking data – PIX key; bank account; bank branch; transaction history and amounts; bank statements; information on financial transactions and payments; cryptocurrency information; credit card data; billing information; payment history;
  • Professional and academic data – Profession; job title; professional email; work address; salary expectations; professional history; academic qualifications; diplomas and other training certificates; company/organization/entity; and other information contained in your resume;
  • Behavioral data – Consumption profile; social media usage history and patterns; preferences; hobbies; cultural fit; financial transaction profile; website traffic data, media data, actions, and campaigns;
  • Sensitive personal data – Data related to your health or political affiliation and classification as PEP (Politically Exposed Person); biometrics;
  • Attributes associated with your electronic devices – Internet service provider; operating system; browser (type, version, enabled options, and installed plugins); video settings (size/resolution and color depth); access date and time; and pages viewed through cookies.

4. Why do we use your information?

The personal data that Bazk collects about you may be used for the following purposes:

To provide our services or execute a contract you have entered into with us.

Data subjects: customers, legal and/or commercial representatives, partners, suppliers, and service providers.

If you are a party to a contract with Bazk, or represent a company in a contract, your personal data will be processed within the contractual limits defined (execution of the contract) or based on our legitimate interest, especially to:

  • Execute and fulfill the contract, comply with our contractual obligations, and provide our services;
  • Register you in our internal systems and grant you access to use our services and platforms;
  • Communicate, attend, and interact as necessary to properly provide our services, such as payment intermediation in the betting market, processing refunds, transaction monitoring and processing, or validating merchant information abroad;
  • Carry out billing and send invoices to our clients or promote the payment to our suppliers and partners.

In these activities, personal data such as registration and qualification data, contact data, financial and banking data, professional and academic data, and behavioral data may be processed.

To comply with our legal or regulatory obligations
Data subjects: customers, legal and/or commercial representatives, partners, suppliers, service providers, and job candidates.

Your personal data may be used to meet our legal obligations (e.g., activities related to Anti-Corruption and Money Laundering laws, issuance of invoices), regulations from governmental bodies (e.g., regulations from BACEN, such as foreign exchange activities), tax authorities, the Judiciary, and/or other competent authorities, such as the Public Prosecutor’s Office, PROCON, among others.

In this process, personal data such as registration and qualification data, contact data, financial and banking data, professional and academic data, behavioral data, and even sensitive personal data may be processed.

To allow the regular exercise of our rights
Data subjects: plaintiffs or defendants or legal/commercial representatives in judicial, administrative, or arbitration processes; whistleblowers, accused individuals, and other parties involved in an internal investigation process.

Even after your relationship with us ends, we may process some of your personal data, such as registration and qualification data, contact data, financial and banking data, professional and academic data, behavioral data, device attributes, and even sensitive personal data, to exercise our rights guaranteed by law, including as evidence in judicial, administrative, or arbitration processes, or within a contract.

We may also process your personal data when we receive reports through our Ethics Channel or Ombudsman, which are designed to process and securely manage reports of violations of Bazk’s compliance rules, whether internal or external, through the provided channels.

You may choose not to identify yourself and remain anonymous or disclose your identity, in which case you will provide registration and qualification data, as well as contact data, which will be processed within the limits of your request to respond, attend, and verify your request and, if necessary, to conduct internal investigations.

To prevent fraud and ensure your security
Data subjects: visitors, guests, clients, service providers, and partners.

We may process your registration and qualification data, as well as sensitive personal data (biometrics), to ensure your (and others’) security and to prevent identity fraud, especially when you enter or visit our premises or to validate your identity.

To conduct advertising activities and communicate with you
Data subjects: individuals who have contacted us; potential clients / leads; clients and legal and/or commercial representatives; partners, suppliers, service providers, website visitors, event participants.

Based on our legitimate interest, we may also process your registration and qualification data, contact data, professional and academic data, behavioral data, and device attributes to:

  • Create target audience segments to appropriately promote precise and updated Bazk campaign content, should you choose to receive them;
  • Communicate with companies, data subjects, and potential clients, directly or through our partners, for personalized marketing purposes related to our services and solutions;
  • Respond to your inquiries, requests, or other interactions with us, via email or phone;
  • Generate mailing lists and send email marketing;
  • Send relevant notices about our activities, such as address changes, corporate structure updates, products, services, promotions, news, updates, events, and other topics you may be interested in; or
  • Send updates that affect your relationship with us in respect of transparency, such as updates to this Notice.

If you interact with our materials and content, we will collect, in addition to your browsing data, your visit data to our pages and other information you choose to share with us. In this case, the option to unsubscribe from our database will always be available at the end of each communication we send, with the option to choose whether or not to receive our mailings. We inform you that in the activities supporting our interests, we will always respect the limits of your expectations, preserving your rights and fundamental freedoms.

To conduct our recruitment and selection activities
Data subjects: job candidates.

Those interested in working with us can submit their resumes through our website under “Check our job openings,” at which point, considering your expectations and our legitimate interest, we will process registration and qualification data, contact data, professional and academic data, and behavioral data to analyze your resume, verify your skills, academic and professional information, and assess whether your profile meets the specific requirements of the position for which you applied.

We will also process your data to contact you (via phone or email) and to facilitate all stages of our selection process, such as scheduling individual interviews.

In exceptional cases, for some of our vacancies, sensitive personal data, such as health-related data, may be collected to fulfill our legal obligation to offer positions to PCD individuals (Law No. 8.213/91) or to comply with regulations, norms, and circulars from BACEN (e.g., Circular No. 3.978).

To facilitate necessary activities for Bazk
Data subjects: individuals who have contacted us; potential clients / leads; clients and legal and/or commercial representatives; partners, suppliers, service providers, website visitors, event participants.

Based on our legitimate interest, we may also process your registration and qualification data, contact data, professional and academic data, behavioral data, and device attributes to:

  • Perform internal activities for validating registrations and relationships with partner banks;
  • Create dashboards, compile indicators, and generate internal reports;
  • Manage our internal database, backups, and monitor the operation of our website and platforms through data analysis;
  • Facilitate and improve relationships with our clients and partners;
  • Manage and optimize the user experience, including through cookies, as outlined in the section below;
  • Manage and maintain our services, including sending alert messages, notifications, and updates, or participating in and organizing events.

All such processing will respect the limits of your expectations and will never be carried out to the detriment of your interests, rights, or fundamental freedoms.

5. What are cookies and how do we use them?

Cookies are text files that can be stored on your electronic devices when you visit our website. Bazk uses this tool for different purposes, such as generating access statistics or enhancing your experience. Below, we list the types of cookies used and their purposes:

Cookie Type

What do they do?

Necessary/Essential

They are essential cookies to enable the proper functioning of our website, as well as to allow you to use all the available features.

Performance/Analysis

These cookies help us understand how visitors interact with our website by providing information about the areas visited, the time spent on the website, and any issues that may have been encountered.

Marketing/Advertising Cookies

These cookies are used to provide more relevant and specific content based on your interests. They may also be used to deliver more targeted advertising or limit the frequency of advertisements shown. Additionally, they help measure the effectiveness of a campaign.

Third-Party Cookies

Third-party cookies are cookies linked to third-party domains.

We emphasize that necessary cookies are essential for the proper functioning of our website. This means that if you oppose the use of this tool, it may impair your experience or suspend your access.

However, you don’t need to worry, as cookies do not damage your equipment and/or electronic device and can easily be disabled by configuring your browser to refuse cookies. In these cases, the website may not function properly, or it may cause excessive delays in loading content.

For more information on how to manage cookies in browsers, we provide the links below:

Internet Explorer

Mozilla Firefox

Google Chrome

Safari

Microsoft Edge

Opera Help

You may also choose to block the use of Google Analytics cookies by visiting the following link: https://tools.google.com/dlpage/gaoptout.

ATTENTION: Disabling the use of necessary cookies may impact your browsing experience.

5. Who do we share your personal data with?

Bazk may share your personal data in certain situations, but only to the minimum extent necessary to achieve the specific purposes that have been previously communicated to you in this Notice.

We may share your data with the following third parties:

Group companies – to facilitate the efficient provision of our services;

Business partners and service providers – to enable audits, risk assessments, communication and marketing services, payments, as well as other necessary structures to operate our services, such as technical support and financial institutions;

Administrative and judicial authorities – when required to comply with legal obligations, respond to BACEN, or assist in the investigation of suspicious or illegal activities; and

Law firms, consultants, and other legal representatives – when necessary to protect Bazk's interests in administrative, arbitral, or judicial proceedings.

In these cases, we use contractual instruments to ensure any third party that receives your data provides adequate protection, following our instructions, including on storage, retention period, and further sharing, when previously authorized.

If there is an international transfer of data, such as to group companies in other countries, this will comply with Brazilian law. International data transfers may occur in the following situations:

Data Destination: Service providers in the United States for cloud data storage
Purpose: Data and information storage for Bazk;
Duration: While we have a purpose for processing/storing your personal data and/or as long as we contract the cloud storage provider;
Security measures: Encryption, access control, audits, and periodic security testing.

Data Destination: Bazk / Inovapay units in Spain, Italy, and Australia
Purpose: To facilitate money transfers abroad and share internal information among group companies to assist top management in making business process decisions;
Duration: Data will be transferred while the commercial relationship persists (in the case of money transfers for merchants);
Security measures: Encryption, access control, audits, and periodic security testing.

Data Destination: Australia, England, South Africa, Curaçao, Malta, Cyprus, and other countries where Bazk operates or where betting operators associated with Bazk are located. In these instances, Bazk ensures data protection via contract and uses legally authorized means for international transfers.
Purpose: To confirm payments to betting operators, facilitate deposits and withdrawals, and monitor transaction processing;
Duration: Up to 5 years after the end of the relationship with the betting operator;
Security measures: Encryption, access control, audits, and periodic security testing.

6. How long do we store your personal data and how do we protect it?


We will not retain your personal data longer than necessary for the purposes stated above, nor will we use your data for other purposes unless authorized by law.

When retention is required beyond the original purpose, the criteria used will include:

  • Legal, regulatory, contractual obligations, or requirements from competent authorities; and
  • The need to maintain accurate historical, business, and financial records or comply with internal organizational requirements.

All storage follows high-security standards and is structured to ensure your rights as established by law. Bazk has internal procedures governing the appropriate and lawful processing of personal data.

These guidelines aim to ensure the proper handling of personal data. In addition to these organizational and governance measures, we employ several technical safeguards to ensure your data is secure, such as:

  • Strict control over data processing, including access limitation and password-protected access;
  • An information security program;
  • Segregation of access to personal data;
  • Training and guidelines for password protection; and
  • Access to services exclusively over secure networks.

7. What are your rights and how can you exercise them with Bazk?


Whatever your relationship with Bazk, you are entitled to all rights regarding your personal data as provided by law, including:

  • Knowing whether we process any of your personal data;
  • Knowing which of your personal data we process;
  • Correcting incomplete, inaccurate, or outdated data, as required by specific regulations when necessary;
  • Requesting anonymization, blocking, or deletion of unnecessary or unlawfully processed data;
  • Requesting data portability to another service or product provider;
  • Requesting deletion of data processed with your consent;
  • Obtaining information about public or private entities with whom we share your data; and
  • Refusing consent when necessary for a processing activity, with an explanation of the consequences of such refusal. You can revoke your consent at any time.

You can exercise your rights at any time, free of charge, by contacting our Data Protection Officer, Brenda Londero Madeira, at dpo@bazk.com. We may require you to verify your identity or provide additional information to confirm the authenticity of your request.

Requests involving personal data or documents of other individuals will not be honored unless you provide a power of attorney, parental authority, or another valid authorization. In some cases, your request may not be fulfilled, and we will explain the reasons for this.

8. Questions and updates


Some of the information in this Notice may be updated or changed, so we advise you to check it periodically.

If you have any questions, you can reach our Data Protection Officer, Brenda Londero Madeira, at dpo@bazk.com. We will notify any changes to this Notice on our homepage.

Date of last update: 05, November, 2024.

Access previous versions of this Notice here.

Term/Expression

Meaning

National Data Protection Authority (ANPD)

It is the federal public administration body responsible for overseeing, implementing, and ensuring compliance with the General Data Protection Law (LGPD) throughout the national territory.

Controller

The individual or legal entity, whether public or private, responsible for making decisions regarding the processing of personal data.

Personal Data

Information related to an identified or identifiable natural person.

Sensitive Personal Data

Any personal data related to racial or ethnic origin, religious beliefs, political opinions, union membership or affiliation to organizations of a religious, philosophical, or political nature, as well as data concerning health, sex life, genetic, or biometric information.

Data Protection Officer (DPO)

Responsible for ensuring that Bazk complies with privacy laws and regulations, safeguarding personal data, and serving as the communication interface with the ANPD and data subjects.

LGPD

General Data Protection Law (Federal Law No. 13,709/2018).

Third Parties

Any individual or legal entity with whom Bazk has or will have a relationship. This includes: service providers, suppliers, consultants, partners, contracted or subcontracted third parties, tenants, space assignees, whether or not there is a formal contract, including those who use the organization's name, supply materials, interact with public officials, the government, or other third parties on behalf of Bazk.

Data Subject

Any identified or identifiable individual to whom the personal data being processed refers (e.g., customer, prospects/leads, job applicant, supplier, partner, etc.).

Processing

Any operation performed with personal data, whether automated or not. This includes the collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, storage, filing, deletion, evaluation, or control of information, as well as modification, communication, transfer, dissemination, or extraction.