Privacy and Data Processing Policies
RESPONSIBLE PARTY AND CONTACTS
Responsible (Controller): INLAZE LTDA. (Commizzion) – CNPJ 61.239.904/0001-69
DPO: dpo@commizzion.com | Legal: legal@commizzion.com | Support: brasil@commizzion.com
SCOPE
Applies to individuals who interact with the Platform and the site in Brazil.
DATA PROCESSED
Identification/contact; account/usage (IP logs/timestamps); B2B operations (billing, KYB/KYC); marketing/support; cookies.
PURPOSES AND BASES
Contract execution; legal obligations; legitimate interest (assessed); consent for non-essential cookies.
RIGHTS OF THE HOLDER
Confirmation, access, correction, anonymization, portability, deletion, sharing information, review of automated decisions.
SHARING AND TRANSFERS
Suppliers acting as intermediaries; international transfers with safeguards.
SECURITY AND INCIDENTS
Technical/administrative measures; notification to ANPD/data subjects where appropriate.
COOKIES AND CONSENT
Level 1 banner (Accept/Reject/Manage) + Level 2 (granularity). Not required, disabled by default; revocation possible.
RETENTION AND ELIMINATION
Retention for legal purposes; deletion/anonymization upon termination.
PARTS AND ROLE
Commizzion as the Publisher's Data Controller and Joint Operator/Controller according to the flow with Operators; the Publisher as the Controller of its data.
INSTRUCTIONS AND PURPOSES
In accordance with the Controller's written instructions and for contractual/legal purposes.
SECURITY AND CONFIDENTIALITY
Reasonable measures (encryption, access control, monitoring, segregation, backup). Staff/sub-managers bound by confidentiality.
ASSISTANT MANAGERS AND TRANSFERS
Cloud, analytics, anti-fraud, KYC, PSPs; international safeguards accepted by ANPD.
INCIDENTS/NOTIFICATION
Notification without undue delay; assistance in rights; reasonable audits; legal preservation; exclusion of indirect damages and economic limit of the main contract, except for fraud/gross negligence.
RIGHTS/COOPERATION
Notification without undue delay; assistance in rights; reasonable audits; legal preservation; exclusion of indirect damages and economic limit of the main contract, except for fraud/gross negligence.
AUDITS
Notification without undue delay; assistance in rights; reasonable audits; legal preservation; exclusion of indirect damages and economic limit of the main contract, except for fraud/gross negligence.
RETENTION/ELIMINATION
Notification without undue delay; assistance in rights; reasonable audits; legal preservation; exclusion of indirect damages and economic limit of the main contract, except for fraud/gross negligence.
RESPONSIBILITY
Notification without undue delay; assistance in rights; reasonable audits; legal preservation; exclusion of indirect damages and economic limit of the main contract, except for fraud/gross negligence.
CONTACTS
DPO: dpo@commizzion.com | Legal: legal@commizzion.com