Introduction
Rivool Finance is a company that provides services for accessing real assets through blockchain tokenization in a practical and efficient manner. To achieve this objective, we need to process personal data, always acting in compliance with the General Data Protection Law.
Our intention is that you understand that by providing information through our software, you will be subject to the conditions of collection, use, storage, and sharing of personal data in accordance with the purposes presented in this document.
We always value transparency in all our processes, which is why our Privacy Policy and Data Protection explains in a straightforward manner how we care for and handle your personal data.
We ask that you read this Policy carefully. Our goal was to make it accessible and clear for your understanding. However, if you have any questions, feel free to contact our Data Protection Officer through email: privacy@rivool.finance
This Privacy Policy complements the provisions of the end-user Terms of Use.
Objectives
This Privacy Policy and Data Protection is intended to demonstrate to you, Data Subject, how Rivool Finance is concerned about your privacy and how we handle your data. We aim to transparently demonstrate our principles and values on this subject to you.
Rivool Finance is committed to respecting and safeguarding your privacy. In doing so, we comply with all applicable legislation in Brazil on this subject, especially the General Data Protection Law (Law 13,709), the Internet Civil Rights Framework (Law 12,965), and the Consumer Code (Law 8,078).
Through this Policy, all issues involving personal data processing will be explained in an accessible manner.
Personal data and processing
Personal Data: Personal data is any information relating to a natural person that makes them identified or identifiable.
Identified: These are those where the information is directly linked to the person who possesses them, allowing their identification. For example: full name, CPF, ID card, driver's license.
Identifiable: These data do not allow direct recognition of the person who possesses them, but within a context of information it is possible to reach their identification. For example: computer IP address, profession, marital status, residential address.
Data Processing: Data Processing refers to any operation performed involving personal data, such as, but not limited to: collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
Data processing agents
Controller: Controller refers to the company that processes personal data for its own purposes; it is the one who defines what will be done with the data. In this Policy, the data controller is us, the company RIVOOL FINANCE BRASIL LTDA, CNPJ 64.108.697/0001-00, a Limited Liability Company, headquartered at Rodovia Admar Gonzaga, 440, Edif America Officenter 5th Floor, Suite 501, Itacorubi, Florianopolis, SC, Brazil, ZIP Code 88034001.
Processor: Processor refers to the third party that processes personal data on behalf of the Controller. We at Rivool Finance work with companies that guarantee the application of measures necessary to protect personal data processed. In this sense, we establish privacy rules for both parties during the business relationship.
Data Subject: Data Subject is the natural person to whom personal data refers.
Data Protection Officer: The Data Protection Officer, also called DPO or Data Protection Officer, is responsible within the company for ensuring the application of legislation and guaranteeing the privacy and security of information. They are also responsible for handling requests from Data Subjects and serving as a communication channel with the National Data Protection Authority (ANPD).
Purpose of data processing
- To enable registration on the Platform and correct user identification
- To carry out public and private offerings of assets
- To allow you to access rights and benefits related to any Tokens acquired through the Platform
- To enable Rivool Finance to contact the user and handle support requests, answer questions, or address complaints regarding the services provided
- To enable transactions involving the purchase of tokens and to validate the financial personal data provided
- To provide all our services within the limits defined in our Terms of Use
- To conduct credit analysis and consult credit information systems (SCR)
- To enable sending marketing emails or other content available free or paid, as well as announcements of new services and products specific to each investor's profile
- To assess the effectiveness and usability of the software
Data processed by Rivool Finance
Regarding:
- Identification, such as Name, Email, Phone
- Whether the person is politically exposed, non-resident or a U.S. national
- Existence of relationship with Rivool Finance
- Source of funds invested in assets, income information and profession
- Purpose of investment and frequency of intended token investments
- Specific information about the asset to be tokenized
- User navigation statistical analysis information
- Financial and registration data essential for credit analysis
Data collection methods
- Through provision by the client themselves
- Through marketing campaigns or subscription to our content downloads
- By filling out our contact form on the official website
- Referral by our business partners
Legal basis
Legal Basis are the circumstances that allow personal data processing by organizations. Rivool Finance only processes personal data that is properly supported by Legal Basis, in accordance with Article 7 of the General Data Protection Law. The Legal Basis used by the company are:
- Contract Execution - Article 7, Section V
- Consent - Article 7, Section I
- Legitimate Interest of the Controller - Article 7, Section IX
- Compliance with Legal Obligation - Article 7, Section II
- Credit Protection - Article 7, Section X
Principles
Rivool Finance is committed to following the principles of the General Data Protection Law. We comply with "Privacy by Design" guidelines, which means that all our services are developed taking into account user Privacy at every stage, and "Privacy by Default" so that the most secure configuration for users is always applied by default.
We follow the principles of LGPD in all data processing. In order to make you more aware of these values and to allow you to verify their compliance, we bring them to this Privacy Policy and Data Protection.
The principles are:
- Purpose
- Necessity
- Adequacy
- Security
- Prevention
- Accountability and Reporting
- Transparency
- Free Access
- Quality
- Non-discrimination
Cookies
What are cookies?
Cookies are files installed on a user's device that allow the collection of certain information, including personal data in some situations, in order to meet various purposes. Among this information, many are essential for the proper and secure operation of web pages and to enable the provision of services in the digital environment.
Why do we use cookies?
To enable efficient navigation between our web pages, remember preferences, and improve user experience. They can also help ensure that the ads you see online are more relevant to you and your interests.
Which cookies do we use?
Session Cookies: Are designed to collect and store information while data subjects access a website.
Functionality Cookies: are used to provide the basic services requested by the user and make it possible to remember preferences of the website or application, such as username, region, or language.
Information security
Rivool Finance is committed to implementing the necessary security standards and measures to ensure all principles of confidentiality, integrity, availability, and authenticity of information. The company is also committed to maintaining the security of personal data you provide through our Platform. We adopt specific technical, organizational, and administrative measures to prevent data breaches and mitigate potential risks. In this sense, Rivool Finance has firewall controls and antivirus on the machines used and conducts regular scans of its equipment.
We communicate to all users that Rivool Finance does not contact you via emails, calls, or SMS requesting confirmation of your personal data. Communication with users occurs through the channels stipulated in our policies and terms.
It is commonly understood that no transmission or data storage system is guaranteed to be entirely secure. Therefore, Rivool Finance asks that users immediately notify the company's Privacy Team if they suspect their information is not protected on our platform.
Contact: privacy@rivool.finance
Data sharing
During the processing of personal data by Rivool Finance, information may be shared or transferred to third parties, in Brazil or abroad, in order to properly comply with LGPD provisions. Data may be shared with: (I) companies belonging to Rivool Finance corporate group and our partners; (II) cloud storage providers and hosting services; and (III) engagement tools related to certain cryptoassets, advertising and marketing activities.
In all circumstances, Rivool Finance is committed to sharing only the personal data strictly necessary to fulfill the specific purpose. For more information about which companies fall under the above circumstances, you can contact us for clarification at: privacy@rivool.finance
Rivool Finance guarantees that, under no circumstances, it commercializes the information of Data Subjects. Additionally, we may share the personal data of Data Subjects with competent authorities in strict compliance with the Law.
Rights of data subjects
Rivool Finance ensures users the exercise of all rights stipulated by the General Data Protection Law, which are:
1st - Confirmation of the existence of personal data processing:
You have the right to confirm with Controllers whether they have your personal data. If you are a Rivool Finance customer, this means we process your data.
2nd - Access to personal data
You can request the Controller to inform and provide the personal data it holds about you.
3rd - Correction of incomplete, inaccurate or outdated personal data
You have the right to request correction or completion of your data from the Controller.
4th - Anonymization, blocking or deletion of unnecessary, excessive or non-compliant data
If any personal data is processed unnecessarily, in excess of its purpose, or in non-compliance with LGPD, you can request that the Controller anonymize, block, or delete such data.
5th - Deletion of personal data processed with consent
If you have given consent for the processing of your personal data, you may request the deletion of such data.
6th - Information about organizations with which the Controller shared personal data
You can request that the Controller inform you which companies your personal data has been shared with.
7th - Information about the possibility of not providing consent and consequences of refusal
If you have questions about providing your consent for specific data processing, you also have the right to receive information about the consequences of not agreeing with the company's terms.
8th - Revocation of consent
If you have given your consent for the processing of your personal data, you can request the revocation of this authorization.
9th - Automated decisions
You can request a review of decisions made solely based on automated processing of personal data that affect your interests.
10th - Data portability
You can request the portability of your personal data to another service provider.
11th - Support for ANPD
You have the right to receive support from the Controller if you wish to file a complaint with the National Data Protection Authority.
12th - Agreement with opposition to irregular processing
You have the right to receive the Controller's agreement to refrain from continuing data processing if it is irregular.
We are committed to addressing all requests from Data Subjects for which we act as Controllers of their data processing. Therefore, we provide a specific channel for you to request information directly from our DPO: privacy@rivool.finance
It is important to note that there are exceptions regarding the deletion of your personal data, when (I) processed for compliance with legal obligation; (II) if the existing contractual relationship with Rivool Finance requires it; (III) if there is another legitimate and justified purpose for maintaining the information. Similarly, access to your Personal Data may be refused if providing such information could reveal Personal Data of other persons or information that could reveal our business secrets.
Policy modification
All personal data processed by Rivool Finance will be in accordance with this Privacy Policy and Data Protection. The company reserves the right to alter this Policy in whole or in part at any time, updating the last date of modification as indicated below.
We ask that you review our Privacy Policy to check for any changes. Nevertheless, we will update our customers and contacts when there are important changes via email.
Data protection officer and certifications
Our Data Protection Officer can be contacted at any time at: privacy@rivool.finance
Their profile with data protection and information security certifications is available at: https://app.exeed.pro/holder/profile/54851
Contact
If after reading this Privacy Policy and Data Protection you still have any questions, you can contact us via our Data Protection Officer's (DPO) email: privacy@rivool.finance
We are always available to clarify your questions!
Review and publication
This Policy will be reviewed within a maximum period of 1 year, but may also be reviewed/modified at any time if necessary, following the company's internal procedures.
The updated version of this policy will be duly made available whenever changed. Publication of this Privacy Policy and Data Protection on the website: February 2023.
Last update date: November 28, 2024.
[End of Privacy Policy]