Privacy Policy
Effective as of 19 December, 2024
See here for the previous version of this Privacy Policy.
This Privacy Policy describes how Feedzai – Consultadoria e Inovação Tecnológica, S.A. and its group companies (“Feedzai,” “we“, “us” or “our“) processes personal information.
This Privacy Policy applies only where Feedzai is a “Controller” (or similar term) under applicable data protection laws – i.e., where we process personal information for our own purposes – and only for the following activities:
- when you use Feedzai’s digital or online properties that link to this Privacy Policy (including as applicable, our website, social media pages, marketing activities, live events and other activities described in this Privacy Policy);
- when Feedzai processes the personal information of our business customers’ employees as part of our administration of our products to those business customers; and
- when Feedzai processes the personal information of our business customers’ end-users in order to deliver our data consortium product to those business customers.
(collectively, the “Products and Services”).
For other of our products or services that we provide to business customers, Feedzai is a “Processor” (or similar term) under applicable data protection laws – i.e., we process personal information on behalf of our business customers and in accordance with their instructions – in which case this Privacy Policy does not apply. Our use of information that we process on behalf of our business customers may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that business customer.
Nothing in this policy contradicts the following statement: Feedzai (and specifically the domain browseranalytic.com) does not collect any data regarding a particular user or device (including IP addresses and user identifiers) on sites or apps not owned by Feedzai, except to perform anti-fraud services. In addition, Feedzai never shares third party provided personal data collected on one customer’s site with other customers or any third party and, except to perform anti-fraud services, never uses or shares such data to create a profile based on a particular user or device. Any retention of such data will be limited to at most 12 months and only as necessary to perform our anti-fraud services.
Feedzai may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.
California Notice at Collection/State Privacy Rights: See the USA State privacy rights section below for important information about your rights under applicable state privacy laws.
NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly).
NOTICE TO AUSTRALIAN USERS: Please see the Notice to Australian Users section below for additional information for individuals located in Australia.
NOTICE TO BRAZILIAN USERS: Please see the Notice to Brazilian Users section below for additional information for individuals located in Brazil.
Index
- Personal information we collect
- How we use your personal information
- Retention
- How we share your personal information
- Your choices
- Other sites and services
- Security
- International data transfers
- Children
- Changes to this Privacy Policy
- How to contact us
- State privacy rights notice
- Notice to European users
- Notice to Australian users
- Notice to Brazilian users
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Products and Services or otherwise includes:
- Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
- End-user contact data, such as our business customers’ end-users’ first and last name, email address, and other identifiers.
- End-user fraud detection data, such as our business customers’ end-users’ transaction details, user behaviour, and identity verification information.
- Demographic data, such as your city, state, country of residence, postal code, and age.
- Support data, such as information sent to us by our business customers for troubleshooting and technical support purposes, e.g., personal information contained within screenshots.
- Communications data based on our exchanges with you, including when you contact us through the Products and Services, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Private sources, such as data providers, social media platforms and data licensors.
- Marketing partners, such as joint marketing partners and event co-sponsors.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Products and Services, our communications and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Products and Services.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
- provide, operate and improve the Products and Services and our business;
- establish and maintain your user account on the Products and Services;
- communicate with you about the Products and Services, including by sending Products and Services-related announcements, updates, security alerts, and support and administrative messages;
- communicate with you about events or contests in which you participate;
- understand your needs and interests, and personalize your experience with the Products and Services and our communications; and
- provide support for the Products and Services, and respond to your requests, questions and feedback.
Service personalization. We may use your personal information to personalize the Products and Services for you, which may include using your personal information to:
- understand your needs and interests;
- personalize your experience with the Products and Services and our Products and Services-related communications; and
- remember your selections and preferences as you navigate the Products and Services.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Products and Services and our business and to develop new products and services.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct Marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
- Targeted advertising. We and our third-party advertising partners may use cookies and other tracking technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Products and Services, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called targeted advertising. We may also share information about our users with these companies to facilitate targeted advertising to those or similar users on other online platforms. You can learn more about your choices for limiting targeted advertising in the Your choices section below.
Service improvement and analytics. We may use your personal information to analyze your usage of the Products and Services, improve the Products and Services, improve the rest of our business, help us understand user activity on the Products and Services, including which pages are most and least visited and how visitors move around the Products and Services, as well as user interactions with our emails, send customer satisfaction surveys and to develop new products and services.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Products and Services; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Products and Services and promote our business.
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Products and Services or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Business partners. We may sometimes share your personal information with partners or enable partners to collect information directly via our Products and Services.
Advertising partners. Third-party advertising companies for the targeted advertising purposes described above.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, courts, court-appointed persons/entities, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Feedzai, financing of Feedzai, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Feedzai as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Feedzai Hotline
In addition to the processing operations set out in this Privacy Policy, Feedzai may process the personal data you choose to provide when submitting a complaint through the Feedzai Hotline.
This data may include i) identification, contact, and professional data of the whistleblower (e.g. name, email, phone number, job role, employer, ii) access number and password of the whistleblower (created when the they submit a report or asks a question in Feedzai Hotline, iii) facts reported by a whistleblower about a suspected violation, including how and where the suspected violation occurred and how they learned about the suspected violation, iv) identity, role, contact details and the employer of the individual(s) allegedly involved in the suspected violation, v) photographs and videos (to the extent legally possible), comments, and other content or information a whistleblower may submit to Feedzai Hotline, and vi) other personal data that may be processed if included in the report or as a work-product of the whistleblower officer/investigators’ inquiries.
This personal data is necessary for Feedzai’s compliance with the legal obligation to establish an internal whistleblowing line (Feedzai Hotline), Feedzai’s legitimate interests in preventing and combating any compliance matters, in order to prevent damages (material and reputational), and violations of laws, rules, regulations, and Feedzai Policies, and Feedzai’s legitimate interests in proceeding, where permitted, with the appropriate disciplinary action and/or claims before the public authorities. These grounds do not cover compulsory notifications made by public authorities under the national and/or other legal obligations.
Your choices
In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.
Access or update your information. If you have an account with us through the Products and Services, you may review and update certain account information by logging into the account.
Opt-out of communications. You may opt-out of marketing-related communications by following the opt-out or unsubscribe instructions at the bottom of the message (for email communications), by replying STOP to our message (for text communications), or by contacting us. Please note that if you choose to opt-out of marketing-related communications, you may continue to receive service-related and other non-marketing communications.
Cookies. For information about cookies employed by the Products and Services and how to control them, see our Cookie Policy.
Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Advertising choices. You may be able to limit use of your information for targeted advertising through the following settings/options/tools:
- Browser settings. Changing your internet web browser settings to block third-party cookies.
- Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
- Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for targeted advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:
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- Google: https://adssettings.google.com/
- Facebook: https://www.facebook.com/about/ads
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- Ad industry tools. Opting out of targeted ads from companies that participate in the following industry opt-out programs:
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- Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp.
- Digital Advertising Alliance: optout.aboutads.info.
- Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for targeted advertising purposes.
You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for targeted advertising purposes.
We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Other sites and services
The Products and Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Retention
We retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
Security
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We may use service providers that operate in other countries, including the United States. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in Europe should read the important information in the ‘Notice to European users’ section about transfers of personal information outside of Europe.
Children
The Products and Services are not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Products and Services from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Products and Services or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Products and Services after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Products and Services and our business.
How to contact us
- Email: privacy@feedzai.com
- Postal address: Rua Pedro Nunes, IPN – Edif. Instituto Pedro Nunes, 3030-199 Coimbra, Portugal
USA State privacy rights notice
Except as otherwise provided, this section applies to residents of California and other USA states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively, the “USA State Privacy Laws”).
This section describes how we collect, use, and share Personal Information of residents of USA states that have privacy laws applicable to us and the rights that residents of such states may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of a USA state with a privacy law applicable to us, you may not be able to exercise these rights.
For purposes of this section, the term “Personal Information” has the meaning given to “personal data”, “personal information” or other similar terms in the USA State Privacy Laws, and “Sensitive Personal Information” has the meaning given to “sensitive personal information,” “sensitive data”, or other similar terms in the USA State Privacy Laws, except that in neither case does such term include information exempted from the scope of the USA State Privacy Laws. In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as job applicants, in which case that notice will apply instead of this section.
Your privacy rights. The USA State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some USA State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with which we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
- Access. You can request a copy of the Personal Information that we have collected about you.
- Appeal. You can appeal our denial of any request validly submitted.
- Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Opt-out.
- Opt-out of certain processing for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.
- Opt-out of profiling/automated decision making. You can opt-out of automated processing or profiling performed on personal information to evaluate, analyze, or predict personal aspects related to a person’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. However, we do not engage in any such profiling/automated decision making that triggers opt-out rights under the State Privacy Laws.
- Opt-out of other sales of personal data. You can opt-out of other sales of your Personal Information. However, as mentioned below, we do not “sell” your Personal Information as that term is defined in the State Privacy Laws.
- Consumers under 16. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.
- Sensitive Personal Information. We do not process Sensitive Personal Information for the purpose of inferring characteristics about consumers under USA State Privacy Laws.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the USA State Privacy Laws.
Exercising your right to information/know, access, appeal, correction, and deletion. You may submit requests to exercise your right to information/know, access, appeal, correction, or deletion by sending us an email at privacy@feedzai.com.
Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information. While we do not sell Personal Information for money, like many companies, we use services that help deliver targeted ads to you as described above. USA State Privacy Laws may classify our use of some of these services as “selling” or “sharing” your Personal Information with the advertising partners that provide the services. You can opt-out of tracking for targeted advertising purposes by visiting our Privacy Preferences Center and turning off targeting cookies, submitting a request via email to privacy@feedzai.com, or by broadcasting the global privacy control (“GPC”) signal from your browser. If our website detects that your browser is transmitting an opt-out preference signal, such as the GPC signal, we will opt that browser out of cookies on our website that result in a “sale” or “sharing” of your personal information. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use to visit our website.
Verification of Identity; Authorized agents. We may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to your information/know, access, appeal, correction, or deletion requests. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law. We also reserve the right to confirm your residency.
Under some USA State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your USA State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
Personal information that we collect, use and disclose. We have summarized the Personal Information we collect and may disclose to third parties by reference below to both the categories defined in the “Personal information we collect” section of this Privacy Policy above and the categories of Personal Information specified in the California Consumer Privacy Act of 2018 (as amended) (Cal. Civ. Code §1798.140) (“CCPA”), and this describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.
Personal Information (“PI”) we collect
CCPA statutory category
Categories of third parties to whom we “disclose” PI for a business purpose
Categories of third parties to whom we “sell” or “share” PI
- Contact data
- Identifiers
- Commercial information
- California customer records
- Affiliates
- Service providers
- Payment processors
- Third parties designated by you
- Business partners
- Advertising partners
- Professional advisors
- Authorities and others
- Business transferees
- Advertising partners
- End-user contact data
- Identifiers
- Commercial information
- California customer records
- Affiliates
- Service providers
- Third parties designated by you
- Business partners
- Professional advisors
- Authorities and others
- Business transferees
- N/A
- End-user fraud detection data
- Identifiers
- Commercial information
- California consumer records
- Internet or Network Information
- Affiliates
- Service providers
- Third parties designated by you
- Business partners
- Professional advisors
- Authorities and others
- Business transferees
- N/A
- Demographic data
- Identifiers
- California customer records
- Affiliates
- Service providers
- Payment processors
- Third parties designated by you
- Business partners
- Advertising partners
- Professional advisors
- Authorities and others
- Business transferees
- Advertising partners
- Support data
- Identifiers
- Commercial information
- California consumer records
- Internet or Network Information
- Affiliates
- Service providers
- Payment processors
- Third parties designated by you
- Business partners
- Professional advisors
- Authorities and others
- Business transferees
- N/A
- Communications data
- Identifiers
- Commercial information
- California consumer records
- Internet or Network Information
- Affiliates
- Service providers
- Payment processors
- Third parties designated by you
- Business partners
- Advertising partners
- Professional advisors
- Authorities and others
- Business transferees
- Advertising partners
- Marketing data
- Identifiers
- Commercial information
- California customer records
- Internet or Network Information
- Affiliates
- Service providers
- Payment processors
- Third parties designated by you
- Business partners
- Advertising partners
- Professional advisors
- Authorities and others
- Business transferees
- Advertising partners
- Payment data
- Commercial information
- Financial information
- California consumer records
- Affiliates
- Service providers
- Payment processors
- Third parties designated by you
- Business partners
- Professional advisors
- Authorities and others
- Business transferees
- Advertising partners
- Device data
- Identifiers
- Internet or Network Information
- Affiliates
- Service providers
- Payment processors
- Third parties designated by you
- Business partners
- Advertising partners
- Professional advisors
- Authorities and others
- Business transferees
- Advertising partners
- Online activity data
- Identifiers
- Commercial information
- Internet or Network Information
- Affiliates
- Service providers
- Payment processors
- Third parties designated by you
- Business partners
- Advertising partners
- Professional advisors
- Authorities and others
- Business transferees
- Advertising partners
- Communication interaction data
- Identifiers
- Commercial information
- California consumer records
- Internet or Network Information
- Affiliates
- Service providers
- Payment processors
- Third parties designated by you
- Business partners
- Advertising partners
- Professional advisors
- Authorities and others
- Business transferees
- Advertising partners
- Data derived from the above
- Inferences
- Affiliates
- Service providers
- Business partners
- Advertising partners
- Professional advisors
- Authorities and others
- Business transferees
- Advertising partners
- Other sensitive Personal Information
We do not intentionally collect this information, but it may be revealed in identity data or other information we collect.
- Protected Classification Characteristics
- N/A
- N/A
Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section, above.
Notice to European users
General
Where this Notice to European users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).
Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”). Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect”.
Controller. Feedzai is the “controller” in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.
Data Protection Officer (“DPO”). You can contact our appointed DPO by sending an email to dpo@feezai.com.
Our legal bases for processing your Personal Information
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.
Our legal bases for processing your Personal Information described in this Privacy Policy are listed below.
- Where we need to process your personal information in order to deliver the Products and Services to you, or where you have asked us to take specific action which requires us to process your personal information (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see the ‘How we use your personal information’ section above and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above.
Purpose
Categories of personal information involved may include
Legal basis
Service delivery and operations
- Contact data
- End-user contact data
- End-user fraud detection data
- Demographic data
- Support data
- Communications data
- Payment data
- Data from third-party sources
- Device data
Legitimate Interests. We have a legitimate interest in ensuring the delivery, ongoing security and proper operation of our Products and Services, our business and associated IT services, systems and networks.
Service personalization
- Contact data
- Demographic data
- Communications data
- Device data
- Online activity data
- Communication interaction data
Legitimate Interests. We have a legitimate interest in providing you with a good service via the Products and Services, which is personalized to you and that remembers your selections and preferences.
Consent, in respect of any optional processing relevant to personalization (including processing directly associated with any optional cookies used for this purpose).
Research and development
- Any and all data types relevant in the circumstances
Legitimate Interests. We have a legitimate interest in taking steps to preserve our users’ privacy as we research how they use our Products and Services.
Direct marketing
- Contact data
- Demographic data
- Communications data
- Marketing data
- Communication interaction data
Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose.
Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Service improvement and analytics
- Contact data
- Demographic data
- Support data
- Communications data
- Device data
- Online activity data
- Communication interaction data
Legitimate Interests. We have a legitimate interest in providing you with a good service and analysing how you use it so that we can improve it over time, as well as developing and growing our business.
Consent, in respect of any optional cookies used for this purpose.
Compliance and protection
- Any and all data types relevant in the circumstances
Compliance with Law.
Legitimate Interests. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety.
To create aggregated, de-identified and/or anonymized data
- Any and all data types relevant in the circumstances
Legitimate Interests. We have a legitimate interest in taking steps to preserve the privacy of our users.
Further uses
- Any and all data types relevant in the circumstances
The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected.
Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the ‘Compliance and protection’ purposes outlined above.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Other information
No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Products and Services to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Products and Services to you. We will notify you if this is the case at the time.
No sensitive information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic other than as requested by us as part of the Products and Services) on or through the Products and Services, or otherwise to us. If you provide us with any such sensitive personal information to us when you use the Products and Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Products and Services.
Your additional rights
General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
- Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
- Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
- Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.
Exercising These Rights. You may submit these requests by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
- For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
- For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/
Data Processing outside Europe
Many of our service providers, advisers, partners or other recipients of data are based outside of Europe, including in the United States. This means that, if you use the Products and Services, your personal information may be accessed and processed in the U.S.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
- Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
- Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S.).
- However, in these cases:
- we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard contractual clauses or other standard-form contracts approved by relevant authorities for this purpose; or
- in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
Notice to Australian Users
Where this Notice to Australian Users applies. The information provided in this ‘Notice to Australian Users’ section applies only to those located in Australia, or otherwise where, in relation to your personal information, we are subject to the privacy law of Australia.
Named entity in Australia. A reference to “Feedzai,” “we“, “us” or “our” under this Privacy Policy is a reference to Feedzai Australia Pty Ltd, with ACN 628 216 713.
How to contact us
- Email: privacy@feedzai.com
- Postal address: Level 9, Grosvenor Place, 225 George Street, Sydney, NSW, 2000
Personal Information. References to personal information in this Privacy Policy should be understood to be a reference to “personal information” as defined under the Privacy Act 2020 (Cth) (Privacy Act).
Sensitive information. Some of the information we collect about you, such as identity verification information, is “sensitive information” as defined under the Privacy Act. By using our Services or providing your sensitive information to us you consent to our collection, use and disclosure of your personal data in accordance with this Policy.
Controller. References to a Controller in this Privacy Policy should be understood as a reference to an “APP entity” as defined under the Privacy Act.
Processor. References to a Processor in this Privacy Policy should be understood as a reference to a “controller”, that is an “APP entity” as defined under the Privacy Act.
Personal information we collect. Please refer to the “Personal information we collect” section above for details about which Personal Information we may process about you.
How we use your personal information. Please refer to the “How we use your personal information” section above for details about this.
How we share your personal information. Please refer to the “How we share your personal information” section above for details about this.
No obligation to provide personal information. You do not have to provide us with your personal information. However, if you choose not to provide us with your personal information or allow us to collect personal information about you, we will be unable to carry out our functions or activities and provide you with our relevant Products or Services.
International data transfer. In addition to those noted, we may disclose your personal information to Feedzai’s group companies in Portugal, USA, UK, Spain, Singapore, Hong-Kong and to the other recipients identified above which may be located worldwide. We try to ensure a similar degree of protection is afforded by using specifically appropriate safeguards, such as standard contractual clauses or other standard-form contracts approved by relevant authorities for this purpose.
Access to and correction of personal information. If you have an account with us you may review and update certain account information by logging into the account. If you do not have an account with us you may request access to or the correction of the personal information held about you by contacting privacy@feedzai.com.
Making a Complaint to us. If you wish to make a complaint about the handling of your personal information or believe we have breached the Privacy Act, please contact us using the details in the “How to contact us” Section above. You will need to provide us with sufficient detail regarding your complaint and any supporting evidence. We will investigate the issue and determine the steps to be taken to resolve the complaint. We will notify you in writing if we require any additional information and also of the outcome of our investigation.
Your Right to Lodge a Complaint with your Supervisory Authority. If you have made a complaint to us and are not happy with the outcome of our investigation, you may complain to the Office of the Australian Information Commissioner by way of their website www.oaic.gov.au or phone hotline 1300 363 992.
Notice to Brazilian Users
General
Where this Notice to Brazilian users applies. The information provided in this ‘Notice to Brazilian users’ section applies only to individuals located in Brazil.
Controller. Feedzai is the “controller” in respect of the processing of your personal information covered by this Privacy Policy for purposes of the LGPD. See the ‘How to contact us’ section above for our contact details.
Data Protection Officer (“DPO”). Our appointed DPO is Lígia Gutierrez Setúbal. You can contact us by sending an email to dpo@feezai.com.
Your additional rights
General. The LGPD gives you certain rights regarding your personal data in certain circumstances. If you are located in Brazil, you may ask us to take the following actions in relation to your personal information that we hold:
- Confirmation. Provide you with information on whether we process your personal data.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Portability. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
- Manage and Withdraw Consent. When we use your personal data based on your consent, you have the right to (i) be informed on the consequences of not giving your consent for a certain purpose, (ii) withdraw that consent at any time, and (iii) request your personal data to be deleted.
- Delete. Delete your personal data where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Review of automated decision making. For processing activities that rely solely on automated decision making, without the input or review by a human person, and which may affect your rights and interests (e.g., on a personal or professional level, on creditworthiness and related aspects), you are entitled to (i) review of such decision and (ii) to be provided with information on the decision making process (to the extent necessary to preserve our confidential information and commercial secrecy).
Exercising These Rights. You may submit these requests by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. All data subject requests are free of charge and may either be answered immediately or within 15 days, depending on the subject matter.
Your right to file a Complaint with ANPD. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal data, you can make a complaint to ANPD using the available means to make a request.
Data Processing outside Brazil. Most of our service providers, advisers, partners or other recipients of data are based outside Brazil, in Europe, and in the United States. This means that, if you use the Products and Services, your personal data may be accessed and processed abroad. We try to ensure a similar degree of protection is afforded by using specifically appropriate safeguards, such as standard contractual clauses or other standard-form contracts approved by relevant authorities for this purpose.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
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Page printed in February 11, 2025. Plase see https://www.feedzai.com/legal/privacy-notice for the latest version.