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Privacy Policy

Latam Access Investimentos S.A, registered with CNPJ 11.180.217/0001-47, headquartered at Av. Brigadeiro Faria Lima, 1800, 7th Floor, São Paulo, SP, CEP 01.451-001, hereinafter referred to as “Latam”, is committed to compliance with laws that protect the data privacy of customers and the general public.  This page is designed to provide information on how we are following data protection standards, what information we collect while you are browsing our communication channels, and how this information is collected, used, and protected by us, in compliance with Law No. 13,709/2018 (General Data Protection Law – “LGPD”). The use of our products and services, as well as our platforms and other available means of interaction, is subject to the acceptance of this Privacy Policy, including regarding our employees.

  1. Source of Personal Data

Latam may have access to personal data in the following situations:

  • Through interaction with a customer:  When the Customer provides and inputs personal data necessary for the provision of services and use of products provided by Latam.
  • Interaction with its employees: When its employees and collaborators of any nature use its systems and platforms to fulfill the duties and obligations arising from their contractual relationship.

2. Types of personal data and sensitive personal data collected

Without prejudice to the data commonly collected and processed from its employees for the purposes of their legal relationship, Latam may still collect the following personal data:

  • Names and contact details, such as first and last name, email address, postal address, telephone number, and other similar types of contact data, such as bank details;
  • Device information, such as information about your device, including IP address, location, or provider;
  • Usage information and browsing history, such as information about how the User navigates within our services, their browsing history, and which elements of Latam's services are most used;

Any sensitive personal data that may be collected by Latam will have its purpose informed separately to the User, who must consent to Latam using it in a specific manner; in case of disagreement, the data will be automatically deleted from Latam's databases.

Latam does not collect data from minors, except with the authorization of parents or guardians. If collected without authorization, as soon as Latam becomes aware, it will immediately delete the collected data, according to the rules of the Terms of Use and this Privacy Policy.

  1. Use of collected personal data

When collected, Latam will use personal data to:

  • Provide and improve the contracted services;
  • Comply with a legal or regulatory obligation;
  • Manage the relationship with Users;
  • Set up and administer User accounts;
  • Provide technical assistance, support, and training to the User;
  • Contact Users;
  • Internal research and development purposes and to improve, test, and refine the features and functions of Latam's services;
  • Provide Users with marketing, advertising, and publicity, including from Partner companies of Latam, as permitted by law;
  • Meet internal and external auditing requirements, including Latam's information security obligations;
  • Send email messages to: a) perform confirmations or cancellations of requests through the use of the platform; b) communicate future changes that this policy may undergo; and c) disclose updates, changes, additions of new data sources, and improvements to the platform.
  • Exercise Latam's rights, including but not limited to the privacy, security, networks, systems, and properties of Latam and/or third parties;
  • Comply with requests from courts, law enforcement authorities, regulatory bodies, and other public institutions and government authorities, including but not limited to any rules in force outside the user's country of residence;
  • The exercise of Latam's rights and to defend against any legal actions, as well as for compliance with any legislation or regulation applicable to Latam or third parties with whom we work, and for the proper fulfillment of contracts signed between Latam and its users;
  1. Sharing personal data with third parties

The User accepts and agrees that Latam may share their personal data with the following categories of recipients:

  • Companies that provide access or are responsible for the registration on which the user is dependent; 
  • Partner companies, such as third-party service providers and other companies that assist us in offering our services or that may take actions on our behalf, protecting our rights, users, systems, and services;
  • Third parties to whom Latam owes accountability or has authorization for information disclosure by law (Example: government bodies, regulatory agencies, the judiciary, and other public authorities);
  • Third parties in order to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, or transfer of part or all of Latam's business, in which case the User's data will be considered an asset and transferred in a potential negotiation;
  • Third parties who require the data to protect Latam's rights;
  • Any natural or legal person to whom the User requests the portability of their data. 
  1. International transfer of personal data 

Latam does not intend to transfer any of the User's captured personal data outside of Brazil; it is certain that if it does not fall under the hypotheses listed below, Users will be previously informed by email, at which time the user may or may not accept the transfer, and in case of disagreement, their access rights may be impeded by Latam. 

The international transfer of data described in the General Data Protection Law (LGPD) requires the designation of guidelines to be established by the National Personal Data Protection Authority (ANPD), and once defined, Latam commits to fully complying with them.

  1. Protection of personal data

Latam uses appropriate technologies and procedures to protect any collected personal data (including administrative, technical, and physical safeguards) according to the risk level and the service provided, having a legally responsible team to handle the secure management of data in line with legal provisions, regulatory requirements, technological changes, and other relevant factors that may influence the way personal data is protected.

Latam employs all reasonable market efforts to ensure the security of its systems and collected data, using highly qualified and reputable Internet providers and database and storage servers, as well as security certificates (SSL) and protection software against unauthorized access to systems, and standard methods for encrypting and anonymizing collected data.

This Policy represents Latam's effort to safeguard the User's information. However, due to the nature of the Internet itself, it is not possible to guarantee that malicious third parties will not succeed in improperly accessing stored information, which is why, should this occur, Latam will be responsible within the limits provided by Law.

Latam, within a reasonable period to be defined by the National Data Protection Authority (“ANPD”), must communicate to the ANPD and the affected User the occurrence of a security incident that may result in relevant risk or damage to the affected User, mentioning, at a minimum:

  • a description of the nature of the affected personal data;
  • information about the data subjects involved;
  • an indication of the technical and security measures used for data protection, respecting commercial and industrial secrets;
  • the risks related to the incident;
  • the reasons for the delay, in case the communication was not immediate; and
  • the measures that were or will be adopted to reverse or mitigate the effects of the loss.
  1. Data processing and LatAm's responsibility.

Latam will have its processing responsibility as follows:

  • When dealing with personal data provided directly by its Clients, Latam will be the Processor, and will act without interference in the processing method indicated by the Controller, but under the terms of the LGPD;
  • Latam will be the Controller of the Personal Data of its employees, processing them based on the Execution of Contracts, Compliance with legal or regulatory obligations, and also, in specific and determined situations, on Consent.

Latam may adopt different legal bases for distinct personal data processing operations.

  1. Personal data processing period

Latam calculates the personal data retention period according to the following criteria:

  • Period necessary to fulfill the purpose of the collection;
  • The moment when the Client/User stops using Latam's services;
  • The moment when there is a withdrawal of consent or a request for deletion of personal data by the Data Subject;
  • The time necessary to demonstrate compliance with Latam's duties and obligations;
  • The necessary period provided for by Law, regulations, court decisions, etc.;
  • Determination by the National Data Protection Authority;
  • Compliance with legal or regulatory obligation by the Controller;
  • Perfect execution of the contract;
  • Needs related to compliance with the legal system, as well as for potential legal disputes;
  • Transfer to a third party, provided that the data processing requirements set forth by law are respected; or
  • Exclusive use by the controller, prohibited from third-party access, provided the data is anonymized.
  1. User Rights

According to the Brazilian General Data Protection Law, the User will have the following rights regarding the processing of their personal data:

  • Right of Confirmation: the User may confirm whether Latam processes any of their personal data;
  • Right of Access: the User may make a written request to obtain details of how their information is being used, as well as to have a copy of said information;
  • Right to Rectification: the User may correct or remove any of their data that is incomplete, inaccurate, or outdated;
  • Right to Anonymization, blocking, or deletion: the User may request the anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in non-compliance with the purposes for which consent was given, observing, for this purpose, other norms of the legal system;
  • Right of Erasure: the User may request the deletion of some data, except those for which the law authorizes retention;
  • Right to Information: The User may request information from public and private entities with which Latam has shared their data, as well as the consequences if they choose not to consent to the collection and processing of their personal data;
  • Right to Refuse Marketing: The User may, at any time, request the cancellation of receipt of advertisements and other materials through the link provided in the sent marketing email. 
  • Right of Portability: The User may request that their personal data be transferred to themselves or third parties, except those that have already been anonymized and deleted by Latam.
  • Right of Withdrawal of Consent: The User may cancel any consent previously granted to Latam to use their personal data. The User is aware that cancellation will not affect the use or sharing of data performed prior to the request for withdrawal of consent.

The rights provided in this chapter are not absolute; the User, whenever they wish to exercise them, must contact Latam through the channel: This email address is being protected from spambots. You need JavaScript enabled to view it.latam-access.com.

Latam commits to fulfilling such requests as soon as possible and at no cost to the User, limited to a maximum period of 15 (fifteen) days from receipt of the request, unless a longer period is necessary to respond due to complexity, factual or legal reasons, in which case the User will be notified.

 Latam will immediately communicate to the processing agents with whom it has shared User data about the correction, deletion, anonymization, or blocking of data, so that they repeat the same procedure.

Confirmation of existence or access to the User's personal data provided for in this chapter will be provided, by electronic means or expressly, in a simplified format or by means of a clear and complete declaration, indicating the origin of the data, the absence of a record, the criteria used, and the purpose of the processing, always observing Latam's commercial and industrial secrets.

  1. Cookies

Latam and any partners may use cookies and other similar technologies to store and manage User preferences, offer targeted advertising, enable content, and collect analytical and usage data, for example. The use of cookies and other tracking technologies is a standard on websites and platforms, through which information about the User's activities on the platform, websites, or other services is collected.

A cookie is a small text file, placed on a computer or other device, used to identify the User, the device used, and to collect information, and can perform the following functions:

  • Necessary Cookies: are essential to allow the User to browse a platform and use its features. 
  • Performance Cookies: they collect information on how the User uses the Latam platform and serve to improve navigation and enhance your experience. The collected information includes, for example, internet browsers and operating systems used, the domain name of the previously visited site, the number of visits, the average duration of the visit, and the pages viewed.
  • Functional Cookies: they allow the platform to remember choices the User made (such as your username or ID, language preference, or the area or region where the User is) and provide enhanced and more personal features.
  • Advertising Cookies: they track User browsing habits and are used to provide targeted advertising. These cookies also limit the number of times you see an ad and measure the effectiveness of advertising campaigns. They also remember that the User has already visited a site, and this information is shared with other organizations, such as advertisers.

Latam uses necessary and performance cookies. 

At any time, the User may disable Cookies through their browser settings, installing available plug-ins, or using other technologies they deem necessary.

In addition to cookies, Latam uses other tracking technologies, such as:

Web Server and Platform Records: Latam's servers automatically collect certain information to assist, administer, and protect the services offered, as well as to analyze use and improve the User experience. Collected information includes:

  • IP address and browser type;
  • Device information, including the Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA), and similar identifiers assigned by us or third parties;
  • The device's operating system and other technical data;
  • The city, state, and country from which you are accessing the platform, including for fraud prevention;
  • Typed information or text;
  • Clicked links and buttons;

Social Media Connections: Some of Latam 's services may include social media features, such as Facebook “Like” buttons and widgets; “Share” button, and interactive mini-programs.

Latam may allow the User to opt to use their own social media logins to access some of the services offered, in which case Latam may receive and store authentication information from those services.

  1. Contact information

Questions, comments, suggestions, and/or complaints regarding this Privacy Policy, as well as any need for information, modification, or deletion of personal data, may be directed by the User directly to Latam, by email: contato@latam-access.com.br

  1. Changes

Latam seeks constant updates and improvements; thus, this Privacy Policy may be updated at any time, always aiming at better service provision and user protection.

In the event of changes affecting the purpose and duration of the User's personal data processing, the User will be informed via the email registered in our services or through the platform itself 30 (thirty) days in advance. If there is disagreement with the changes, the User may withdraw the provided consent, becoming unable to use Latam's services.

If in the future Latam should change its policy to allow for data sharing with third parties, it will send a notice 30 (thirty) days in advance to the user via the registered email, and the user may disagree with the sharing, in which case they will continue using Latam's services.

The User is advised to periodically read this policy to stay updated on its content.

  1. Legislation and Jurisdiction

This Policy will be governed, interpreted, and executed in accordance with the laws of the Federative Republic of Brazil, regardless of conflicts between these laws and the laws of other states or countries. The Courts of São Paulo shall be competent to settle any doubts arising from this instrument, with the waiver of any other, however privileged it may be.

All rights reserved.