Privacy Policy

 

Privacy Policy

Our Privacy Policy is addressed to individuals outside of our organization with whom we interact, including visitors to our website, customers, potential customers, corporate clients' personnel, client representatives, family members, office staff, suppliers and suppliers' personnel, other recipients of our services, and anyone who contacts our service centers or Ombudsman (collectively, “you”).

This Privacy Policy may be changed or updated from time to time to reflect changes in our practices regarding the Processing of Personal Data or changes in applicable law. We encourage you to read this Privacy Policy carefully and to regularly check this page to review any changes we may make in accordance with the terms of this Policy.

Processing Your Personal Data

Collection of Personal Data

We collect Personal Data about you from various sources, as follows:

  • We obtain your Personal Data when you provide it to us (e.g., when you contact us via email or telephone, or by any other means).
  • We collect your Personal Data in the normal course of our relationship with you (e.g., during the performance of our services or in the management of your transactions or investments).
  • We collect Personal Data that you manifestly choose to make public, including through social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).
  • We receive your Personal Data from third parties who provide it to us (e.g., your employer; our clients; credit reference agencies; and law enforcement authorities).

  • We receive your Personal Data from third parties, where you purchase any of our products or services through those third parties.

  • We collect or obtain Personal Data when you visit our Website or use any features available through it. When you visit a website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connection to a website, and other technical communication information), some of which may constitute Personal Data.

Creation of Personal Data

We create Personal Data about you, such as records of your interactions with us and details of your accounts, subject to applicable law.

Processing Your Sensitive Personal Data

We do not seek to collect or Process your Sensitive Personal Data, except when:

  • Processing is necessary for compliance with a legal obligation (e.g., to meet our diversity-related obligations or when we become aware of information that may be considered Sensitive Personal Data, such as your political opinions, when we carry out necessary checks for compliance with a law or regulation);
  • rocessing is necessary to protect your life or physical safety or that of a third party, as permitted by applicable law;
  • rocessing is necessary to ensure the prevention of fraud and your security in the process of identification and authentication of registration in electronic systems;
  • ou have publicly manifested this Sensitive Personal Data;
  • rocessing is necessary for our regular exercise of rights in contracts, in judicial, administrative, or arbitration proceedings;
  • e have obtained, in accordance with applicable law, your explicit consent prior to the Processing of your Sensitive Personal Data (as above, this legal basis is used only in relation to Processing that is entirely voluntary—it is not used for Processing that is necessary or mandatory in any form); or
  • he processing is necessary for the execution of public policies provided for in laws and regulations.

Processing Third-Party Personal Data

In any case, if you provide us with Personal Data of third parties, you will be responsible for informing those third parties that their personal data has been transferred to us and for informing them that this policy will apply. You are also responsible for collecting and recording their consent, if consent is required by law and such obligation is legally imposed on you.

Last updated in November 2025.

 

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