1. General Aspects
1.1. This Policy is based on the Banco Inter's pillars - experience, partnership, transparency, security and simplicity. Through those pillars, Banco Inter reaffirms its commitment to the privacy and security in the handling of collected information from customers and users of the Digital Media, as well as on the financial products and services offered by the Banco Inter (“Users" or “User", when considered individually).
1.2. This Policy applies to all the Users, as well as to the officers, employees, suppliers, third parties and others involved on the Banco Inter's activities.
1.3. This Policy is available for reading at any time on the Digital Media.
2.1.1. The User understands that such consent may be revoked at any time upon request to the Banco Inter. At its request, the User’s collected information will be deleted by the Banco Inter, except if its storage is required by law.
2.2. The User acknowledges to be solely responsible for any made registration on the Digital Media as well as for the veracity of the provided information to Banco Inter on the initial registration and/or in a subsequent access to the Digital Media. The User acknowledges that Banco Inter has no responsibility for the provided information accuracy, as well as for any damages arising from the inaccuracy of the information.
2.2.1. In adittion, the User understands that Banco Inter may, in its sole discretion, perform any searchs that it deems necessary to determine any incorrect, untrue or outdated information, as well as request additional information and/or documents in order to check the registration information provided by the User.
2.2.2. If Banco Inter decides to verify the veracity of the User's registration information and finds the existence of incorrect, untrue and/or outdated information, or, also, if the User refuses to inform the required information, Banco Inter may, temporarily or permanently, suspend, at its discretion, the User's access to the Digital Media and also the sending of advertising content, without prejudice to other measures deemed necessary.
3. User Information
3.1. Banco Inter gathers User’s information in 3 (three) ways:
(a) Information provided by the User – these are information provided by the User himself when interacting, contracting or using any of the offered products or services on the Digital Media, such as:
- Personal data, such as: name, address, social security number, e-mail and phone number.
- Professional and income data.
(b) Information collected by Banco Inter – these are information arising from User's activities on the Digital Media, such as:
- Any information collected regarding the use of the products or services offered by Banco Inter, including, but not limited to the financial transactions, payments, mobile recharges, debit and/or credit operations, investment, insurance and other banking services.
- Access data obtained by the devices used by the User to access the Digital Media, including the device specifications.
- Access data collected by cookies and similar technologies in order to understand the User’s interactions with the Digital Media.
(c) Information provided by third parties – these are information collected by Banco Inter from external sources:
- Information collected from external sources such as information bureaus in order to validate some reported data by Users.
- Statistical data of User’s behavior on the Digital Media, provided by data analysis systems.
3.2. The User acknowledges and agrees to the collection, storage, processing and use of the submitted or transmitted information by the User as set forth in this Policy.
4. Data Processing
4.1. All of the actively provided information by the User such as name, personal data and e-mail, as well as those automatically generated information, such as the access device characteristics, internet protocol (“IP”), access information, geolocation data, application history and login data are received and stored in a secure environment of Banco Inter's database.
4.2. Banco Inter uses data collected through the use of Digital Media by Users to (i) perform statistical analysis; (ii) develop and improve the products and services offered; (iii) identify the specific needs of each User and, thus, offer personalized products through campaigns aimed at each User profile.
4.2.1. The information obtained through devices such as location and IP are used by Banco Inter to increase transaction security, making it possible to act in real time towards unusual movements evetually made by an User.
4.2.2. Banco Inter also uses the collected information in order to send e-mails and notifications to the Users regarding the use of Digital Media to the User, as well as the availability of new products.
4.3. The access to collected information, pursuant to this instrument, is restricted to authorized and qualified professionals who need it exclusively for the performance of their duties.
4.4. The User may, at any time, through Banco Inter call centers, correct or update the provided information through the Digital Media.
4.5. The User understands that all of the information provided by him/her or collected by Banco Inter is considered to be confidential and, therefore, Banco Inter undertakes to take all the technical and administrative measures to protect the personal data as well as the systems used to store the information, including the guidelines on security standards set forth in Decree No. 8.771 / 2016, such as:
(a) Use of industry standard methods to encrypt and anonymize collected data as well as other standard forms of encryption to ensure its inviolability;
(b) Use of high-tech protection software against unauthorized access to Banco Inter's systems, which are considered controlled and security environments;
(c) Availability of access to personal data storage facilities only to previously authorized people, who must be committed to the confidentiality of such data, including by signing a confidentiality agreement;
(d) Application of records access authentication mechanisms capable of individualizing the responsible one for processing and accessing the collected data as a result of the use of Digital Media; and
(e) Maintenance of an inventory indicating the time, duration, employee or access worker identity as well as the object file, based on the connection and application access records, as determined in article 13 of Decree 8.771/2016.
4.6. The User understands that Banco Inter may share the collected data with third parties in the following hypotheses:
(a) When necessary for Banco Inter's business activities, indispensable for the provision of the service and/or necessary to improve the User experience with the products and services offered by Banco Inter, such as advertising, profiling, payment, among others, events in which it will be signed a confidentiality agreement with the respective company in order to guarantee the strict confidentiality of the information;
(b) For the protection of Banco Inter’s interests in the event of conflict, including but not limited to court proceedings;
(c) In the event of transactions and/or corporate moves involving Banco Inter, in which case the transfer of data will be necessary for the continuation of the services offered on the Digital Media; or
(d) By court order or at the request of administrative authorities with legal competence for addressing its request.
4.7. Banco Inter respects the regulation of bank secrecy and will not share information from its Users, except by legal or judicial determination. All of the data transmission, dealt with in this item 4, will be placed on a safe environment, anonymously, that is, without the disclosure of personal information that enables the User identification.
4.8. Banco Inter will exclude collected information when: (i) the purpose for which the information was collected is achieved or when the data is no longer necessary or relevant to the achievement of this purpose, as described in this Policy; (ii) upon the consent withdrawal by the User, when it is necessary; or (iii) upon the competent authority determination to do so.
4.8.1. The User understands that the exclusion of certain data may affect the provision of products and services by Banco Inter, without any indemnification due by Banco Inter due to such exclusion.
5. User's Rights Regarding the Processing of Personal Data
5.1. Banco Inter guarantees the User, as regards the processing of his/her personal data, the following rights:
(a) Confirmation of his/her personal data processing;
(b) Access to his/her collected data by Banco Inter from the use of the Digital Media;
(c) The correction of your data if it is incomplete, inaccurate or out of date;
(d) The anonymizing, blocking or deleting of unnecessary or excessive data, as well as those treated in violation of the Brazilian applicable law;
(e) The portability of his/her personal data, to him/herself or to third parties, upon express request by the User;
(f) The exclusion of the personal data processed with his/her consent, provided that the minimum information storage period determined by Brazilian law must be respected;
(g) Information about the public or private entities with which Banco Inter has shared his/her information; and
(h) Information about the possibility of not giving your consent to the processing of your personal data, as well as being informed of its consequences.
6. Third Parties Relationship
6.1. This Policy only refer to the use of Banco Inter's Digital Media, and do not include third party websites, which eventually remain on our pages or which indicate our Digital Media in an external environment.
6.2. Banco Inter requests to its services partners to comply with its Ethics Code and Security Information Policy, observing the same standards of security as Banco Inter do.
7. Intellectual Property
7.1. Banco Inter ensure that information, such as text, images, domain name, brand, slogan, sounds and/or applications, software and features contained in its digital documents, are in compliance with the laws that rule the trademarks and patents, and may not modify, copy, reproduce, quote or otherwise use for commercial purposes without the prior express consent of Banco Inter.
7.2. All of the text, images, photographs, trademarks, logos, icons, technologies, links and other audiovisual content made available on Banco Inter's Digital Media, including graphic designs and source codes, are the exclusive property of Banco Inter, and are protected by law and international pacts, being forbidden its copy, reproduction, or any other use. The violators are subject to civil and criminal sanctions, pursuant to Brazilian Federal Laws n. 9.279/96, 9.609/98 and 9.610/98.
7.3. If the User identifies the breach of intellectual property rights, the User may send a complaint through Banco Inter's service channels to find out the indicated situation and take the necessary measures to investigate and settle any irregularity.
8. Limitation of Liability
8.1. Banco Inter shall not be liable to:
(a) for any error or failure at Digital Media that’s turn it out of service, as well as for any difficulty of access;
(b) inconsistencies in data transmission or in the quality of the Internet connection, which prevent the proper use of Digital Media;
(c) presence of computer viruses or any harmful elements in the Digital Media;
(d) any damages arising from any harmful elements inserted by third parties;
(e) damages arising out of the unauthorized accessed by third-parties of any information, as a result of User or third-parties failure, that are beyond control of Banco Inter; and
(f) for any inaccurate or outdated information provided by the User upon registration with the Digital Media.
9.1. Without prejudice to other remedies available, Banco Inter may, in its discretion, suspend, temporarily or permanently, the User access to Digital Media, initiate legal actions or suspend the provision of its services if:
(a) The User breach any of the provisions of these Policy or the provisions of any other documents that regulates the relationship between User and Banco Inter;
(b) Banco Inter suspect that the User has committed any fraud or illegal acts; and
(c) If it is not possible to verify the identity of the User or if the information provided by the User is incorrect.
10.1. If any provision or condition of these Policy is, for any reason, adjudged void or ineffective, will not affect the validity and effective of other provisions of these Policy.
10.2. No failure to exercise or delay in exercising any right, remedy, power or privilege of Banco Inter provided by law or under this Policy shall be construed or operate as a waiver of such right, remedy, power or privilege, nor shall any single or partial exercise of any right, remedy, power or privilege preclude any other or further exercise thereof.
10.3. Banco Inter may change this Policy from time to time, at its discretion, to make conform with laws and regulations or to adapt with the updated versions of the Digital Medias. All changes will become effective when posted in Digital Medias, unless indicated otherwise. Banco Inter encourage Users to regularly check our Digital Medias to review any changes we might make. If User have any comments, question or concerns about any of the information in this Policy should contact Banco Inter or it will be considered that the Policy was acept.
11. Applicable Law
11.1. This Policy shall be governed by Brazilian law. All disputes arising from or in connection with the Policy shall exclusively be submitted to the competent Court in Belo Horizonte, State of Minas Gerais, Brazil. Banco Inter may choose, in its own discretion, for the Court in the city of the User.