We process personal information for the purposes set out in this Privacy Policy observing legal bases. Our legal basis for processing your personal information will depend on the personal information in question and the specific context in which we collect it, but will include when it is:

– necessary for the performance of Commerce Private Limited (for example, to provide the services requested by you and to identify and authenticate you so that you can use the Platform).

– necessary to comply with legal requirements (for example, to comply with applicable accounting rules and make required disclosures to law enforcement authorities);

– necessary to achieve our legitimate interests or those of third parties;

– based on your consent;

– necessary for the regular exercise of rights in judicial, administrative and arbitration proceedings;

– necessary for the protection of life and limb or of the data subject and third parties;

– used for credit protection purposes;

– used for other cases foreseen  or applicable legislation.

If we collect and use your personal information based on our (or a third party’s) legitimate interest, that interest will generally be to operate our Platform and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate business interest, for example in responding to your inquiries, improving our Platform and services, conducting marketing, or for the purpose of ensuring the security of our Platform and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information). In some cases, it may be necessary for you to provide us with personal information for processing as described above in order for us to provide you with all of our services and for you to use all of the features of our Platform.

If you have questions or need more information about the legal basis on which we collect and use your personal information, please contact us using the contact information provided in section O. HOW TO CONTACT US below.

Your Rights

You have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided in section O. HOW TO CONTACT US below:

– The right to access your personal data and confirm the existence of processing.

– The right to correct, update or request anonymization, blocking or deletion of your personal information.

– The right to object to the processing of your personal information where it is based on our legitimate interests or in case of non-compliance with LGPD or applicable law.

– The right to ask us, in some situations, to restrict the processing of your personal information or to request portability of your personal information.

– The right to cancel marketing communications we send you at any time. You may exercise this right by clicking on the “unsubscribe” or “unsubscribe” link in marketing e-mails that we have sent to you. To unsubscribe from receiving other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact information provided in section O. HOW TO CONTACT US below.

– If we collect and process your personal information with your consent, you have the right to withdraw your consent at any time and request deletion of your personal data. Withdrawing your consent will not affect the lawfulness of any processing carried out prior to your withdrawal, nor will it affect processing of your personal information carried out on a legal basis other than consent.

– The right to request a review of decisions based solely on automated processing, which may affect your interests.

– The right to petition the National Data Protection Authority – ANPD about our collection and use of your personal information.

– The right to request portability of your personal data to another service provider;

– The right to request information about with whom your personal data has been shared.

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. If you are aware of changes or inaccuracies in your information, you must inform us of such changes so that our records can be updated or corrected.

To exercise your rights, you or your authorized legal representative may contact us using the contact details provided in section O. HOW TO CONTACT US below. Once we receive your request, we may verify it by requesting sufficient information to confirm your identity, including requesting that you verify information about your use of the Platform.

M. INTERNATIONAL TRANSFERS OF PERSONAL DATA

In connection with providing the services through our Platform, we will store your personal data processed through the Platform in the United States, Russia, Germany and/or Singapore, depending on the country you are located in. These countries have data protection laws that may have different provisions to the laws of your country. There will also be international transfers of your information among the above-mentioned countries. We take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement appropriate measures to ensure your personal information will remain protected in accordance with this Privacy Policy, such as standard contractual clauses or other mechanism provided for in the applicable law. A copy of the relevant clauses can be obtained by contacting us using the contact details provided under section O. HOW TO CONTACT US below.

N. LANGUAGE

If there is any conflict between the English version and another language version of this Privacy Policy, the English version shall prevail.

O.HOW TO CONTACT US

Contact information: [email protected]