Sinky Privacy Policy
Last updated: August 2024
These Terms of Use provide the conditions and rules for you, User, to visit our page, register, and enjoy the services offered. Therefore, we kindly ask you to read this document carefully, as these terms will regulate our relationship with you and explain how our Platform works and how we offer Services to Users.
A Sinky is an online platform accessible via the URL https://besinky.com/ ("Platform"), developed and made available by Sinky Inc Ltda, registered with CNPJ under no. 52.472.052/0001-64, headquartered at Rua Cardeal Arcoverde, no. 2365, Conjunto: 33 - Parte, Pinheiros neighborhood, in the City of São Paulo, State of São Paulo, ZIP 05407-003 ("Sinky," "we," or "our").
The Platform (i) provides a tool for users (generically referred to as "Users," "you," or "your") so that Users themselves can perform real-time inquiries of information contained in various public and private base platforms available, as chosen by the User; and (ii) mediates the relationship of the User with the Credit Intelligence Manager S.A., issuer of the credit report ("Services").
Some specific functionalities provided by Sinky require prior registration on the Platform.
In our Terms of Use, we explain in detail how our Platform works. The Platform can be accessed by individuals who use our Services without the need to create an account ("Visitors"), or by registered users who wish to access specific functionalities of the Platform, who must provide us with certain information.
This Privacy Policy ("Policy") explains, in a simple, objective, and transparent manner, what Personal Data is collected, used, and otherwise processed by Sinky and for what purposes, in addition to indicating with whom they may be shared and how Users can manage their Personal Data.
It is not possible to offer the functionalities and Services of the Platform without having access to this Personal Data. That is, the processing of Personal Data is a condition to use the Platform and the Services.
Please read this Policy carefully to understand how we use your Data on our Platform. To facilitate your reading, we have organized this Policy according to items listed in the index below.
The Personal Data we collect through your registration on the Platform will allow you to access the Services and certain functionalities of the Platform, as described in our Terms of Use. We also collect Personal Data related to your use and behavior within our Platform.
Through this Policy, we want to provide you with transparency about which Personal Data we collect and use about you on the Platform. We remind you that some of your Personal Data may be shared with third parties for the effective provision of Services and availability of the Platform.
Therefore, the Personal Data is provided by you and used so that we can, in general:
• Register you on the Platform;
• Authenticate your identity;
• Communicate with you whenever necessary;
• Make available and improve the functionalities of the Platform.
Personal Data is collected, used, and processed based on different legal grounds (as provided in the General Data Protection Law, the “GDPL”), such as: contract execution; legitimate interest; fraud prevention; consent; among other legal bases provided for in the GDPL.
If, after reading this Policy, you still have any questions, or for any reason need to contact us regarding issues involving your Personal Data, you can reach out through the channels below:
Responsible: Paulo Rodrigues
Email: dpo@besinky.com
Privacy Committee
Email: privacidade@besinky.com
We do not collect or knowingly solicit Personal Data from individuals under the age of 18. Users under the age of 18 should not attempt to register for access to the Platform or send us any Personal Data. If we become aware that we have collected information from an individual under the age of 18, we will cancel the account created on the Platform and delete the Personal Data.
Sinky will act as the Personal Data Controller for its Users as long as it is competent to make decisions regarding the processing of Personal Data, as described below.
Sinky receives or otherwise collects information related to the registration and verification of Users and information related to the use of the Platform by Users and Visitors directly through registration and navigation on the Platform, hiring our Services, contacting our Communication Centers, among other means, such as complaints and comments directly involving Sinky and/or the Platform in complaint channels and social media.
Regarding the Personal Data collected from our Users, we act as Controllers for the following purposes:
The information requested and provided directly by the Individual User when registering and requesting Services on the Platform:
• Full name
• Email
• Password
• CPF
• Date of birth
• Mobile phone (optional)
The Administrator will be responsible for indicating the email and the Name of the Collaborators who will have access to the Platform to benefit from the Services and functionalities available for Institutional Users. The Administrator declares and guarantees that they have legitimacy (and legal bases) to provide the Personal Data of these Collaborators to Sinky and for the creation of their registration with the Platform.
These are the information related to the User-Collaborator, requested and provided directly by the Administrator or by the User-Collaborator themselves, to register on the Platform:
• Full name
• Email
• Password
• Social Security Number (SSN)
• Date of birth
• Mobile phone (optional)
The Collaborator may change or update their Personal Data when provided by the Administrator, directly via the Platform.
(C). User Activity Personal Data
We collect information related to the use of the Platform and the activities that Visitors and Users perform during its use, such as:
• Type and version of Browser
• Pages visited on the Platform
• Referring page
• Duration of use of the Platform
• Viewing paths of the Platform
• IP Address / IPv6
• Geolocation
• Type of access device (mobile/computer)
• Screen resolution
• Cookies
• Mouse movement (“heatmap”)
• Clicks / taps
• Screen / content scrolls
• History of queries and reports issued on the Platform in the last 6 months (applicable only to Users)
Regarding third-party Personal Data provided by our Users, we act as Operators, pursuant to the LGPD, for the following purposes:
(D). Personal Data of Third Parties
They refer to Personal Data voluntarily provided by Users to make inquiries, under the terms defined by the User. The Personal Data will depend on the type of research conducted by the User, who declares and guarantees that they have obtained the Personal Data through lawful means and will use them within legal guidelines, especially in relation to the LGPD.
The tool provided by Sinky allows Users to make inquiries for information available on various platforms of public government databases, as chosen by the User. The User may only use the information for legitimate purposes, such as preventing fraud and money laundering, complying with anti-corruption measures, fulfilling legal and regulatory obligations, Know Your Client (KYC), Know Your Partner (KYP), Know Your Supplier (KYS), Know Your Employee (KYE). Sinky makes no decision regarding which data will be collected through its tools by the User.
As indicated in the User Activity Personal Data, we may use certain tracking technologies for activities performed on the Platform. The information collected through such technologies is used to perform performance metrics of the Platform, identify usage issues, capture User behavior in general, and collect content impression data. The third-party technologies we use for tracking and that collect information are: Cookies, Intercom, Google Analytics, Twitter Ads, Facebook Analytics, LinkeIn, Hotjar, and RD Station.
About Cookies: A cookie is a text file placed on the hard drive by a web server, with no ability to run programs or infect your computer with viruses. On our Platform, the use of cookies serves to personalize your online experience, saving your time and optimizing your navigation.
We use cookies to automatically collect browsing data, including information such as device type (mobile or computer, for example), browser, accessed pages, search terms, among others. We use cookies to identify general characteristics of our audience (profile) and to adapt our service to provide you with a better experience.
Cookies help us provide a better website that aligns with your habits and preferences. It is worth noting that it is possible to disable the use of cookies in your browser settings; however, some functionalities of the Platform may stop working correctly if that is your choice.
All information that can identify you individually, directly or indirectly, is used for the purposes described below.
Users
• Perform and validate the registration and identification of Users with the Platform, including via email and/or SMS;
• Link your Platform account with third-party social networks;
• Enable User access to the Platform through identity authentication;
• Provision of Service; Contact with the User when necessary, through the provided means;
• Sending necessary communications, announcements, and customized alerts according to the User's profile and their geolocation;
• Clarification of doubts and complaints and management of communication channels;
• Provide balance and credit statement for consultation on the Platform;
• Issuance of billing invoices (viewing balance and credit statement);
• To comply with the Civil Rights Framework for the Internet regarding the retention of IPs and access logs for at least 6 (six) months;
• Compliance with legal, regulatory, and agency obligations;
• Sending and monitoring marketing emails;
• Fraud verification;
• Conducting internal audits;
• Complying with judicial decisions or other authorities as determined by law;
• Judicial, administrative, or arbitration processes. We may use the personal data collected to investigate and instruct eventual judicial, administrative, or arbitration processes in which we may be involved.
Administrator
• Allow the management of the Institution and User registration;
• Verify the Institution and the Administrator's link with the Institution.
User Activity Personal Data
• Platform customization according to User experience;
• Statistical purposes for improving the functionalities of the Platform and Sinky;
• Security of internal processes and provided Services;
• Regionalization of Users, aiming for performance improvements;
• Usability, aiming for improvements in the services provided;
• Conducting internal audits;
• Statistical identification of the access path to the Platform;
• Making available the history of consultations and reports made by Users for a period of 6 (six) months.
We structured the Platform and our operations so that your Personal Data is not kept in an identifiable manner for longer than necessary. That is to say, we keep Personal Data only for the period during which it is necessary for the purposes described above, if we are required by law, or if we have any other legitimate reason to retain it.
Therefore, we may keep your Personal Data, among other reasons, to comply with legal obligations, exercise rights in legal actions, administrative and/or arbitration procedures, and combat fraud. We may also keep Personal Data in an anonymized manner, that is, without such data being or being able to be related to you, for longer periods, as permitted by law.
Personal Activity Data
Intercom, Google Analytics, Twitter Ads, Facebook Analytics, LinkedIn, Hotjar, and RD Station
Statistical analysis of the Platform;
Marketing direction;
Usability analysis;
Content personalization
Users
PagSeguro
Process payments made through the Platform for the purchase of Services;
Sending confirmation of the purchase made via the Platform.
Judicial or governmental authorities
Companies and employees of the same economic group
Service Providers
Advertisers and other business partners
To comply with requests made by judicial or governmental authorities, as provided by applicable law or regulation.
Provision of the services offered by the Platform
Improvement of the functionalities of the Platform and the services provided
Sinky requires all service providers with whom it shares Users' Personal Data to include in their contracts provisions that ensure proper protection, secrecy, and confidentiality in the processing of personal data.
Allow the development of the Platform's activities.
Enable the improvement of the Platform's services and operations.
We may share for marketing purposes and allow advertisers or business partners to select their respective ads or promotional offers, according to the User Activity Data.
Collaborators
Administrators
Allow the Administrator and the Institutions to manage and monitor the Operators' profiles.
The User has rights and guarantees regarding their Personal Data. We provide mechanisms, detailed below, so that Users have clarity and transparency in exercising their rights. Whenever necessary, our team will be ready to meet potential requests.
As provided in the LGPD, regarding your Personal Data, Users have the rights to request:
• confirmation that we process your Personal Data;
• access to your Personal Data;
• correction of Personal Data that is incomplete, inaccurate, or outdated;
• anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed Personal Data;
• portability of your Personal Data to another service or product provider, respecting our trade and industrial secrets, after regulation by the National Data Protection Authority;
• deletion of Personal Data processed based on your consent, except in cases of retention of Personal Data as provided in the LGPD;
• information about whom we share your Personal Data with;
• information about the possibility of not providing your consent and the consequences;
• revocation of your consent for the processing of your Personal Data when the Personal Data is processed based on your Consent.
You can exercise any of the rights above by sending an email through (i) our support suporte@besinky.com, (i) any of our Digital Channels; or (iii) the contact details of the Officer: dpo@besinky.com.
We protect the rights of Users regarding their Personal Data, according to applicable law and as provided in this Policy. You can use our Platform to manage your Personal Data.
When you are logged into the Platform, you will be able to verify all Personal Data provided to Sinky during your registration and can change it through the Platform itself, in the area of your profile.
If you stop using the Platform, your Personal Data will continue to be protected by this Privacy Policy and will continue to be stored in our database, only if necessary for the fulfillment of some purpose duly associated with a legal hypothesis validating it.
You may request the permanent deletion of the Personal Data you provided to Sinky, which will promote the proper deletion of the respective Personal Data, while maintaining some Personal Data for the purposes of (i) mandatory record-keeping as provided by applicable law; (ii) necessary retention for the regular exercise of rights by Sinky. Personal Data related to Users' interactions and submitted content (such as actions, communications, comments, etc.) will be retained on our Platform.
To use our Services again after the deletion of your Personal Data, you will need to register again and repeat all necessary procedures, as provided in the Terms of Use.
Your Personal Data collected is stored on Amazon Web Services servers in Brazil. We will take all reasonably necessary and available precautions to ensure that your Personal Data is stored securely and in accordance with this Privacy Policy.
We store your Personal Data securely in restricted access locations, for the period provided by applicable law.
We adopt the best technical and administrative practices to protect Personal Data from unauthorized access, destruction, loss, alteration, communication, or any form of inappropriate or illegal processing.
At the same time, we cannot guarantee that the site is a completely secure environment. If you have any concerns or suspicions that your Personal Data is at risk, for example, if someone has gained access to your password, please contact us immediately by sending an email to “meajuda@besinky.com” or “suporte@besinky.com”.
If your Personal Data is transferred to another country during the provision of Services or operation of Sinky by Sinky or third parties described above, we (and the third parties, when applicable) will take the measures required by law to ensure that your Personal Data remains protected.
If you wish to request the deletion of your account, please send an email to “suporte@besinky.com” with the subject "Account Deletion" and the following information:
Full name
CPF
Email registered on Sinky
Reason for deletion (optional)
The sender of the email must be the same one used to create the account, to ensure that no one else is impersonating you.
You will receive a confirmation email as soon as your account is deleted.
If you have remaining credits in your account, requesting deletion will cause your credits to be lost, with no possibility of redemption.
In order to ensure the maximum security of you and your data, we emphasize that your access password on our site is personal and non-transferable. It is important that you know this and protect your password, as well as limit the use and access of it exclusively to your computer and devices, preventing any unauthorized access to your account. It is your sole responsibility to maintain your access password in a secure and restricted access location.
In this regard, it is necessary that it is not obvious like birthdays or words found in dictionaries. It is important that the password is composed of special characters and alphanumeric characters, and that it is changed periodically or in case of suspected unauthorized access.
If you, for any reason, believe or suspect that your password or account has been accessed improperly, we ask that you contact our Support Center immediately.
Sinky does not use your email address for any purpose other than sending institutional information and advertising content. If you do not wish to receive this type of email anymore, just click on the “opt out” link in the footer of the email;
We will not ask for any personal data from you via email (such as password, username, CPF, enrollment, etc.). Therefore, if you receive any suspicious email in our name, please forward it to the Support Center for us to analyze and take the appropriate action.
In order to provide a safer environment for Users, we employ security measures to prevent misuse, loss, unauthorized access, disclosure, and alteration of User accounts, such as data encryption, firewalls, and access authorization controls for Personal Data.
Although Sinky has a duty of confidentiality regarding your Personal Data, under this Privacy Policy, it is the responsibility of each User to protect and maintain the confidentiality of their logins, passwords, and other account access information, as well as to verify that the Personal Data we hold about the User is correct.
We will strive to protect the Personal Data of our Users and other information that we keep in our records; however, we cannot guarantee the utmost security of our Users. Unauthorized access or use, hardware or software failure, and other factors may compromise the security of User information at any time.
IN THIS SENSE, THE TRANSMISSION OF INFORMATION OVER THE INTERNET IS NOT COMPLETELY SECURE DUE TO VARIOUS FACTORS, INCLUDING NETWORK AND OPERATIONAL FACTORS, AND SINKY CANNOT GUARANTEE COMPLETE SECURITY OF DATA TRANSMITTED BY USERS TO THE PLATFORM. ALTHOUGH WE DO OUR BEST TO PROTECT USERS' PERSONAL DATA, WE CANNOT GUARANTEE THE SECURITY OF PERSONAL DATA TRANSMITTED TO OUR PLATFORM. ANY TRANSMISSION IS SOLELY THE RESPONSIBILITY OF THE USERS, WHO, BY AGREEING TO THIS POLICY, EXPRESSLY RECOGNIZE AND ASSUME SUCH RESPONSIBILITY.
Once Personal Data from the User is received by the Platform, we commit to ensuring that it will be secure within the Platform environment. To prevent unauthorized access or disclosure of the User's Personal Data, we have implemented appropriate physical, electronic, and administrative procedures to ensure and protect the information we collect.
You are responsible for: (i) all and any acts or omissions made from your access; (ii) any and all products purchased through the Platform; and (iii) personal information sent and transmitted on or from the Platform.
Our Platform is under continuous development and may contain errors. We do not guarantee that (i) the functions contained on the site will meet your needs; (ii) the operation of the site will be uninterrupted or free of errors; (iii) all functionalities will be permanently available; (iv) defects will be corrected or that the Platform will be compatible and will work on any device, with another application, software, or third-party services.
Furthermore, we do not assure that our Platform will be free from loss, interruption, attack, virus, interference, hacking, or other security invasions and, therefore, we are not liable for failures of this nature. It will be your responsibility to install an antivirus system.
The LGPD establishes several situations in which the processing of Personal Data is permitted regardless of the consent of the data subject. These are the so-called "legal bases for data processing."
This means that if you choose to use the Platform, in some cases we may collect and process your Personal Data regardless of your consent (if there is a "legal basis" provided in the LGPD that allows us to do so), such as for the execution of preliminary measures for hiring or for the execution of a contract with you, for compliance with legal and regulatory obligations, for the regular exercise of rights in contracts or in judicial, administrative, and arbitration processes, for credit protection, for ensuring the prevention of fraud and the security of the data subject, in the processes of identification and authentication of registration in electronic systems, for legitimate interests of Sinky or third parties, among others. In other cases, we will ask for your consent to use your Personal Data.
We may change the provisions of this Policy at our discretion and at any time.
Whenever we materially change this Policy, those changes will be valid, effective, and binding after: (1) being disclosed on our Platform; or (2) being sent to you by email; or (3) being communicated to you in another way.
You should check the updated version of this Policy every time you visit our Platform.
If you do not agree with the changes, you may not continue using the Platform and the Services.
You can file a complaint through any of Sinky's contacts listed at the beginning of this Policy and by the Support Center.
