Privacy Policy

COLORTRADE will have access to personal data in the following situations:

• Through interaction with a customer: When the customer provides and imputes personal data necessary for the provision of services and use of the products provided by COLORTRADE.
• Interaction with your collaborators: When your employees and collaborators of any nature use their systems and platforms to comply with the duties and obligations arising from the contractual relationship they have.

Without prejudice to the date commonly collected and processed by its employees for the purposes of the legal relationship they have, COLORTRADE may still collect the following personal data:

• Names and contact details, such as first and last names, e-mail addresses, postal address, telephone number, and other similar types of contact information, such as bank details;
• Device information, such as information about your device, such as IP address, location, or provider;
• Usage information and browsing history, such as information about how the User navigates within our services, his browsing history and which elements of COLORTRADE services are most used;

The sensitive personal data, which may eventually be collected by COLORTRADE will have its purpose informed separately to the User, who must consent to COLORTRADE to use them in a specific way, and in case of disagreement the data will be automatically deleted from the COLORTRADE databases.

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

When collected, COLORTRADE will use personal data to:

• Provide and improve contracted services;
• Comply with a legal or regulatory obligation;
• Manage the relationship with Users;
• Set up and manage Users accounts;
• Provide technical assistance, support and training to the User;
• Contact Users;
• Internal research and development purposes and to improve, test to improve the features and functions of COLORTRADE services;
• Provide Users with Marketing, advertising, including from COLORTRADE Partner companies as permitted by law ;
• Meet internal and external audit requirements including COLORTRADE’s information security obligations;
• Send messages by e-mail to: a) confirm or cancel requests through the use of the platform; b)
  communicate future changes that the present police may undergo; and c) disseminate updates, changes, inclusion of new data sources and improvements to the platform.
•  To exercise the rights of COLORTRADE including but not limited to the privacy, security, networks, systems and properties of COLORTRADE 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 COLORTRADE’s rights and to defend itself from possible legal actions, as well as to comply with legislation or regulation applicable to COLORTRADE or third parties with whom we work, as well as for the exercise of good compliance with contracts signed between COLORTRADE and it users;

The User accepts and agrees that COLORTRADE shares its personal data with the following categories of recipient:

• 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 can take action on our behalf, protecting our rights, users, systems and services;
• Third parties for which COLORTRADE must be satisfied or authorized to disclose information by law (Example: Government agencies, regulatory agencies, the judiciary and other public authorities);
• Third parties in order to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, transfer of part or all of COLORTRADE’s business, in which case the User’s data will be considered an asset and transferred in an eventual negotiation;
• Third parties that need the data to protect the rights of COLORTRADE;
• Any natural or legal person for whom the User requests the portability of their data.

COLORTRADE does not intend to carry out the transfer of any personal data of the User capture outside of Brazil, being certain that in case the hypotheses below are not listed, the Users will be previously
informed by email, at which time the user may accept or not the transfer, and in case of disagreement, your access rights may be prevented by COLORTRADE.

The international data transfer described in the General Data Protection Law (LGPD) requires the assignment of guidelines to be established by the National Personal Data Protection Authority (NPD), while, when defined, COLORTRADE will commit to comply with them in their entirety.

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

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

This Policy represents COLORTRADE's effort to safeguard User information. However, due to the very nature of the Internet, it is not possible to guarantee that malicious third parties will not be successful in improperly accessing the stored information, which is why, if this occurs, COLORTRADE will be liable within the limits provided by law.

COLORTRADE, within a reasonable period to be defined by the National Data Protection Authority (“ANPD”), shall report to the ANPD and the affected User the occurrence of a security incident that may
cause relevant risk or damage to the affected User, mentioning, in the Minimum:

• A description of the nature of the affected personal data;
• The information about the holders involved;
• The indication of the technical and security measures used for data protection, observing commercial and industrial secrets;
• The risks related to the incident;
• The reasons for the delay, in case the communication was not immediate; and
• Measures which have been or will be adopted to reverse or mitigate the effects of the loss.

COLORTRADE will have its treatments responsibility as follows:

• When dealing with personal data provided directly by its Customers, COLORTRADE will be an Operator, and will act without interference on the form of treatment indicated by the Controller, but under the terms of the LGPD;
• COLORTRADE will be the Controller of the Personal Data of its collaborators then based on the Execution of Contracts, on the Compliance with legal or regulatory obligations, and, in specific and determined situations, on Consent.

COLORTRADE may adopted different legal bases for different treatment of personal data.

COLORTRADE calculates the retention period for personal data according to the following criteria:

• Period necessary to fulfill the purpose of the collection;
• The moment when the Client/User stops using the services of COLORTRADE;
• The moment when the Holder has revoked the consent or request for the elimination of personal data;
• The time required to demonstrate compliance with COLORTRADE’s duties and obligation;
• The necessary period foreseen by Law, regulations, judicial decisions, between others;
• Determination of the National Data Protection Authority;
• Compliance with legal or regulatory obligation by the Controller;
• Perfect contract execution;
• Needs regarding the observance of the legal system, as well as for possible legal disputes;
• Transfer to a third parties, provided that the data processing requirements provided for by law are respected; or
•  Exclusive use of the controller, being forbidden to access it by a third party, and provided the data is anonymized.

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

• Confirmation Right: the User will be able to confirm whether COLORTRADE carries out the treatment of any personal data of his;
• Right of Access: the User may make a written request to obtain details of how his information is being used, as well as to have a copy of said information;
• Right to Correction: The User may correct or remove any date that its incomplete, inaccurate or out of date;
• Anonymization, blocking or deletion right: the User may request the anonymization, blocking or elimination of unnecessary, excessive or treated data in disagreement with the purpose to which he gave consent, observing, for this purpose, other rules of the legal system.
• Exclusion Right: the User may request the deletion of some data, except for those in which the law
  authorizes in conservation;
• Right of Information: the User may request information from public and private entities with which COLORTRADE has shared the use of his data, as well as the consequences if he choose not to consent to the collection and treatment of his personal data;
• Right to Refuse Marketing: the User may, at any time, request the cancellation of the receipt of advertisements and other materials through the link provided in the email marketing sent.
• Portability Right: the User may request that his personal data be transferred to himself or to third parties, except those that have already been anonymized and excluded by COLORTRADE
• Right of Revocation of Consent: the User may cancel any consent previously granted to COLORTRADE to use his personal data. The user is aware that the cancellation will not affect the use or sharing of data made prior to the request for revocation of consent.

The rights provided for in this chapter are not absolute, and the User, whenever he wants to exercise then, contact COLORTRADE through the channel: This email address is being protected from spambots. You need JavaScript enabled to view it.

COLORTRADE undertakes to respond to such requests as soon as possible and at no cost to the User, limiting itself to a maximum period of 15 (fifteen) days from the receipt of the request, unless a longer period is required to respond due to complexity, reasons of fact or of law, opportunity in which the User will be communicated.

COLORTRADE will immediately communicate to the treatment agents with whom it has made shared use of User data on the correction. deletion, anonymization, or blocking of the data, so that they repeat
the same procedure.

Confirmation of the existence or access to the User’s personal data provided for in this chapter will be provided, either electronically or expressly, in a simplified format or by means of a clear and complete declaration, which indicates the origin of the data, the lack of registration, the criteria used and the purpose of the treatment, being always observed the commercial and industrial aspects of
COLORTRADE.

COLORTRADE and any partners may use cookies and other similar technologies to store and manage User preferences, off targeted advertising, enable content and collect analytical and usage data, for
example. The use of cookies and other tracking technologies is 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 followings functions:

• Necessary Cookies: they are essential to allow the User to navigate on a platform and use its resources.
• Performance Cookies: they collect information on how the User uses the COLORTRADE perform and serve to improve your browsing and enhance experience. The information collected includes, for example, internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, the average duration of the visit and pages viewed.
• Functional Cookies: they allow the platform to recall choices that the User has made (such as their username or ID, language preference or the area or region where the User is) and provide enhanced and more persona features. l
• Advertising Cookies: they track the User’s 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 website and this information is shared with other organizations, as an advertiser.

COLORTRADE uses necessary and performance cookies. 

At any time, the User may disable Cookies through the settings of his browser, installing plug-ins available on the market, or using other technologies that he deems necessary.

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

Web Server and Platform Records: COLORTRADE servers automatically collect certain information to assist, manage and protect the services offered, as well to analyze usage and improve the User
experience. The information collected includes:

• IP Address and browser type;
• Device information, including the Unique Device Identifier (UDID), MAC address, Advertising Identifier (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 BRAZIL RISKS platform, including fraud prevention;
• Typed informations or texts;
• Clicked links and buttons;

Connections via Social Networks: Some of COLORTRADE’s services may include social networking features, such as Facebook “Like” buttons and widgets; “Share” button and interactive mini programs.

COLORTRADE may allow the User to choose the logins of their own social networks to access some of the services offered, in which case COLORTRADE may receive and store authentication information to
these services.

Questions, comments, suggestions and/or complaints related to this Privacy Policy, as well as any need for information, alteration or deletion of personal data, may be made by the User directly to COLORTRADE, by email: This email address is being protected from spambots. You need JavaScript enabled to view it.

COLORTRADE constantly seeks updates and improvements, so this Privacy Polity can be updated at any time, always aiming at a better performance and protections to users.

In the event of changes that affect the purpose and duration of the treatment of the User’s personal data, the User will be informed through the email registered in our services or through the platform itself 30 (thirty) days in advance. If there a disagreement with the changes, the User may revoke the consent provided, being unable to use the services of COLORTRADE.

If COLORTRADE changes its policy in the future in order to share data with third parties, it will send notice with 30 (thirty) days in advance to the user through the registered email, which may disagree
with the sharing, and will continue to use COLORTRADE’s services.

The User is advised to periodically read this policy so that he/she can keep up to date on its content.

This policy will be governed, interpreted and executed in accordance with the laws of the Federative Republic of Brazil, regardless of the conflicts of these laws with the São Paulo Forum competent to resolve any doubts arising from the instrument, with waiver of any other, however privileged it may be.

All rights reserved.