PRIVACY POLICY
Welcome to UnblockPay!
UnblockPay has developed its platform (“Platform”) based on principles of security, transparency, and compliance. We are committed to ensuring that users’ experience in trading crypto assets is not only efficient but also supported by applicable legal requirements and regulations for Virtual Asset Service Providers.
In order to improve our Platform and provide our services, UnblockPay processes personal data. As we recognize the importance of your privacy, we have developed this Policy so that you, our User (and the general public), understand: (i) how we process personal data; (ii) what security measures we apply to keep your data protected and secure; (iii) what your rights are under the General Data Protection Law; and (iv) the contact channel for you to exercise these rights.
The use of the Platform is not intended for children and adolescents. Therefore, do not register or use the Platform if you are not at least 18 (eighteen) years of age.
Key Definitions:
Many of the terms used in the Privacy Policy (“Policy”) are provided for in Law No. 13,709/2018, known as the General Data Protection Law (“LGPD”). To facilitate your understanding and reading, we present in this glossary the main terms we use.
When reading the terms described below, whether in upper or lower case, plural or singular, bold or not, they should be interpreted as follows:
a) Personal Data: Information that identifies a natural person (i.e., an individual), either directly—name or CPF number, for example—or indirectly—such as address or financial data;
b) Sensitive Personal Data: Data about racial or ethnic origin, religious beliefs, political opinions, union membership, or membership in religious, philosophical, or political organizations, data related to health or sex life, genetic or biometric data, when linked to a natural person;
c) Database: a structured set of data, including personal data, established in one or more locations, in electronic or physical form;
d) Data Subject: natural person to whom the personal data being processed refers;
e) Controller: natural or legal person, under public or private law, responsible for decisions regarding the processing of personal data. In this case, the Controller of the Personal Data entered on the Platform will be the Contracting Party, which holds the license for the Platform;
f) Processor: natural or legal person, under public or private law, who processes personal data on behalf of the Controller. In this case, UnblockPay acts as the Processor with regard to the personal data entered by its Users on the Platform;
g) Processing: any operation performed on personal data, such as those related to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination, or extraction;
h) Legal Bases: These are the legal grounds that legitimize, i.e., enable the processing of personal data.
If you would like to know more about the General Data Protection Law, you can access it directly at the Brazilian Federal government website. If you have any questions about any concept in this Policy and would like to know more about it, you can contact us to clarify any doubts through the contact information provided in the summary table.
1. GENERAL TERMS
1.1. General. UnblockPay (UNBLOCK SERVICOS DIGITAIS LTDA) registered with CNPJ No. 58.444.469/0001-08, headquartered in the city of Rio de Janeiro, state of Rio de Janeiro, at Av. das Americas, No. 700, Block 6, Room No. 236, Barra da Tijuca, ZIP Code 22640-100, considers the use of personal data to be a matter of extreme importance and seriousness. For this reason, this Policy has been developed to communicate practices related to the processing of personal data, especially related to the collection, use, and processing of information that Users provide through the platform.
1.2. Authorization for Processing. By using UnblockPay's Platform, the User authorizes the processing of personal data and agrees to be bound to the UnblockPay Platform. If you do not accept the practices and policies described in this particular instrument, you will not be able to use the platform.
1.3. Regulation. UnblockPay operates in accordance with Brazilian law, including, in particular, the terms of Law No. 12,965/2014 ("Civil Rights Framework for the Internet"), Law No. 13,709/2018 ("LGPD"), Law 14,478/2022 ("Law on Virtual Asset Service Providers") and other rules that may apply.
1.4. Contact. If you have any questions or suggestions about the platform's Privacy Policy, you can contact the data protection officer ("DPO") by email at hello@unblockpay.com.
1.5. Information Control. This Policy describes what personal data may be processed from Users while using the platform's services, how this information may be used, and the precautions taken against unauthorized access or use of this information.
1.6. Registration Update. UnblockPay may periodically request that Users update their registration data, in accordance with the rules of the Central Bank of Brazil and other applicable regulations. Failure to comply with such requests may result in access limitations or suspension of use of the Services until the regularization is completed.
2. REGISTERED PERSONAL DATA
2.1. Processing of Users' Personal Data. UnblockPay may process the following information and/or personal data of Legal Entity Users and their legal representatives: (a) Company name; (b) CNPJ/Tax ID; (c) Address; (d) Country; (e) Phone number; (f) Email; (g) Full Name (legal representative); (h) CPF/Tax ID (legal representative); (i) Passport/Driver's License (legal representative); (j) Date of birth; (legal representative).
2.2. Processing of Users' Financial Data. UnblockPay may also collect, store, and use the following information: (a) Bank details (bank, account number, branch); (b) Transaction records on the Platform/Application; (c) Transaction history and digital wallets;
2.3. Processing of Users' Technical Data. UnblockPay may also collect, store, and use the following information: IP address.
3. HOW UNBLOCKPAY USES THE REGISTERED DATA
3.1. Use. By agreeing to this Policy, Users agree that UnblockPay may process the data collected by the Platform for the purpose of: (a) identify and register Users on the platform and make services available to Users; (b) ensure that the platform's content is presented in the most efficient way to adapt the User experience, offering more relevant and effective service; (c) ensure that user accounts are secure and that access to data is restricted to the Users themselves; (d) help make general improvements to the platform; (e) ensure that the platform complies with all applicable data protection regulations and standards; (f) contact and notify Users about changes to the platform or its policies and terms of use, when necessary; (g) send newsletters and informational emails.
3.2. Data statistics. UnblockPay may use the information collected from Users to generate statistics that will be used for the continuous improvement of the services offered, ensuring that the features and offers more effectively meet the needs of Users.
3.3. Data anonymization. All information collected that may be used for the formulation of statistics, analyses, or studies will undergo an anonymization process. This means that any identifiable personal data will be removed or altered so that Users cannot be identified directly or indirectly. The company is committed to using technologies and practices that ensure the irreversibility of the anonymization process, guaranteeing that anonymized data cannot be reversed to reveal the identity of Users.
3.4. Data Anonymization Process. The company adopts a robust anonymization process to ensure the security and privacy of User data. This process involves the following steps: (a) Removal of Direct Identifiers: Information such as name, email, phone number, and other direct identifiers are removed from the data sets, ensuring that Users cannot be directly identified; (b) Data Aggregation: Data is grouped in such a way as to prevent the identification of specific individuals. Analysis is conducted only on collective patterns and trends, ensuring that individual information cannot be isolated; (c) Anonymization Techniques: Advanced techniques, such as randomization and generalization, are applied to ensure that data cannot be traced back to a specific User. These techniques alter or replace information in the data sets in such a way that any attempt at identification is unfeasible.
3.5. Monitoring and recording of communications. UnblockPay may monitor or record communications made by telephone, email, or chat with its users, exclusively for security, internal training, and customer service quality improvement purposes
4. SHARING OF PROCESSED PERSONAL DATA
4.1. Sharing. UnblockPay does not disclose to third parties any personal data provided by Users through the UnblockPay platform, except: (a) Cases in which UnblockPay is required to disclose or share the personal data processed in order to comply with a court order, or for the purposes of preventing fraud or other crimes, as well as in response to a request for information submitted by a competent authority, if we believe that the disclosure is in accordance with or required by applicable laws, regulations, or procedural procedures; (b) To protect the rights, property, or safety of UnblockPay and the Platform; (c) With law enforcement agents and/or government authorities, if it is understood that your actions are inconsistent with the provisions in our terms of use, or to protect the rights, property, or safety of UnblockPay, its Users, or others; (d) Upon the User's own action; (e) In cases of partial or total sale of the business or its assets, or as part of any reorganization or restructuring of the business, merger, spin-off, or incorporation, so that UnblockPay may share User information with third parties that are part of the respective businesses, taking the necessary measures to ensure that privacy rights continue to be protected in accordance with this Policy.
4.2. International sharing. UnblockPay may transfer your personal data internationally, strictly complying with the requirements set forth in the General Data Protection Law (LGPD), adopting technical, legal, and organizational measures to ensure the adequate and secure protection of the personal data transferred. When we carry out international transfers, we ensure that adequate safeguards are in place to protect personal data, including, where required by law, the conclusion of Standard Contractual Clauses approved by the European Commission or other legal mechanisms recognized by applicable laws.
4.3. Non-sharing of data with third parties. UnblockPay undertakes not to share the data collected with third parties, and all data provided by users will be used exclusively for the internal purposes described in item 3.2.
5. ACCESS AND CORRECTION OF PERSONAL DATA
5.1. Access and Rectification of Personal Data.
Users have the right to access their personal data processed by UnblockPay, as determined by the LGPD, by contacting the DPO via email at compliance@unblockpay.com, which will be answered during business hours, Monday through Friday, from 8 a.m. to 8 p.m., within 15 (fifteen) days and may be sent by email or letter, in accordance with the provisions of Article 9 of the LGPD, in order to ensure the following rights: (a) Right to confirmation of processing: the right to request confirmation of the processing of your personal data through clear information about the origin of the data, the absence of records, the criteria used, and the purpose of the processing; (b) Right of access: the right to be informed and request access to personal data processed by UnblockPay; (c) Right of rectification: the right to request that UnblockPay change or update your personal data when it is incorrect or incomplete; (d) Right of deletion: the right to request the deletion of the data subject's personal data or, if this is not possible (due to mandatory retention, as provided for by law), to keep it for the period provided for by law on an inactive basis; (e) Right to data portability: the right to transfer the data subject's personal data for use by third-party services; (f) Review of automated decisions: the right to request a review of decisions made solely by automated means.
5.2. Exception to the Request for Deletion. The User has the right to request the deletion of their personal data stored on the platform at any time, except in cases where there is a legal obligation or court decision to maintain the storage of data, in accordance with the provisions of Articles 18, VI and 16, I, both of the LGPD.
5.3. Incorrect Information. It is the User's responsibility to keep their information up to date, and in the event of any inaccuracy, UnblockPay may update or delete it, except in cases where it is necessary to maintain it for legitimate commercial or legal purposes.
5.4. Necessary Protection Measures. UnblockPay takes the necessary security measures to protect Users' personal data and to protect them against loss, misuse, unauthorized access, disclosure, alteration, or destruction.
5.5. Password Protection. Users are also responsible for taking appropriate measures to protect their passwords, usernames, and other special access features to their personal registration on the platform.
5.6. Responsibility. Users are responsible for: (i) keep their access credentials (login and password) secure and not share them with third parties; (ii) use secure devices and networks, keeping systems and antivirus software up to date; (iii) immediately report any suspicion or knowledge of unauthorized access or security incidents.
6. NOTIFICATION OF CHANGES TO THE PRIVACY POLICY
6.1. Changes to the Privacy Policy. UnblockPay may change this Policy from time to time. The use of processed information is subject to the Privacy Policy in force. If UnblockPay makes changes to the way it processes personal data, it will notify Users by sending an email.
6.2. Tacit acceptance. Minor adjustments to this Policy may occur without significantly affecting the way UnblockPay processes personal data, so these will not need to be communicated.
7. COMMUNICATION
7.1. Sending Communications. By registering, Users agree that UnblockPay may send notifications to their email address regarding services and important information about the use of the platform that require their attention.
7.2. Anti-Spam Policy. The platform takes the necessary precautions to prevent the unsolicited sending of emails.
7.3. Confidentiality. The highest degree of confidentiality is ensured in the handling of data such as email lists during UnblockPay's regular administrative tasks.
8. RETENTION AND STORAGE OF PERSONAL DATA
8.1. Retention and storage. The LGPD does not stipulate a specific period for retaining personal data. However, it determines that storage must be carried out within a reasonable period. UnblockPay will store User data for as long as the User's registration is active.
8.2. Retention period. Personal data is stored for a period considered appropriate based on applicable Brazilian law, namely: (a) 6 (six) months for the registration of Platform activities, as provided for in Article 15 of the Brazilian Civil Rights Framework for the Internet; (b) 5 (five) years for information relating to the processing of personal data, as this is the period for which UnblockPay may be audited and/or sued, as well as under the terms of the Money Laundering Prevention rules – Law No. 9,613/98 and associated regulations.
8.2.1. In cases where retention is necessary, the data subject will be informed of this impossibility of deletion, if requested by them, and will not be used for purposes other than those provided for in this topic.
8.3. Data characteristics. Retention includes personal registration and usage data of theUser, as well as records of interactions and related information, which we retain for a period of six (6) years from (i) the cancellation of the User's account; or (ii) the provision of personal data by the data subject (when not a User of the Platform) in contact forms or similar.
8.3.1. In cases where there is an administrative or judicial proceeding or inspection activity or audit in progress, UnblockPay may extend this period until the end of the procedure in question.
9. PERSONAL DATA SECURITY
9.1. Storage. Users' personal data and all platform information are stored and transmitted securely, and only employees authorized by UnblockPay may access your personal information, subject to confidentiality obligations and strict respect for your privacy under the terms of this Policy.
9.2. Information security. Personal data is transmitted and stored on AWS (Amazon Web Services) servers. All interactions on the platform, including those related to the transfer and sharing of information with public agencies, are encrypted and subject to data backup, monitoring tools, security policies, and access controls for employees, using up-to-date security software.
9.3. Notification. If UnblockPay becomes aware of any breach of its own security or that of the hosting companies it uses, including intrusions, data leaks, or any other information security incident, it will notify the competent authorities and any affected Users of such breach and will provide as many details as possible regarding the nature, extent of the breach, and the compromised data, within a reasonable time, in accordance with the provisions of Articles 48, § 1, of the LGPD.
9.3.1. Technical measures and incidents. UnblockPay adopts advanced technical security measures, including encryption, firewalls, periodic security tests (pen tests), and regular audits. In the event of incidents involving personal data, UnblockPay will promptly notify affected users and take immediate measures to mitigate any damage.
9.3.2. Restricted access. Access to personal data is strictly limited to professionals or employees who need this data to carry out the purposes mentioned in this Policy, including compliance, information security, and customer service teams, through access control based on authorization profiles. When required by law, data may be shared with competent authorities, such as the Central Bank of Brazil, COAF, or judicial authorities, always observing confidentiality, the specific purpose, and the principles of the LGPD.
10. OUR OFFICIAL CUSTOMER SERVICE CHANNELS
10.1. Questions or suggestions. In case of questions or suggestions about the Privacy Policy or any other information related to the document, the User may request support by email at
10.2. Hours of operation. Support hours are from 8:00 a.m. to 8:00 p.m., Brasília time (GMT-3). Our support aims not only to resolve potential problems quickly and efficiently, but also to seek an amicable solution.
11. GENERAL PROVISIONS
11.1. User Responsibility. Users will be responsible for compensating UnblockPay for all costs and damages it may incur as a result of their violation of this Privacy Policy.
11.2. Cooperation with Authorities. UnblockPay fully cooperates with any authorities or courts that may request the disclosure of the identity or location of any person who has posted any material on the platform that violates the provisions of this Policy.
11.3. Cookies. UnblockPay does not process cookies on its website or app.
11.4. Applicable law and jurisdiction. This Privacy Policy is governed by Brazilian law, with the jurisdiction of the District of Rio de Janeiro being defined as competent to settle any disputes arising therefrom, to the detriment of any other, however privileged it may be or become, with priority always being given to attempts at resolution through conciliation or mediation.
11.5. Limitation of Liability. This Privacy Policy only addresses the processing of personal data provided to the platform. If the User discloses their information to third-party websites, different rules may apply to the use of their information.
Revision control:
- Date: 09/29/2025
- Activity: Issuance of the document
- Version: 1.0.