Privacy Policy

This Privacy Policy (“Policy”) explains how Broad Fintech Ltd (“Broad”, “us”, “we”, “our”) uses the personal data we collect from You when you use our apps, website or any other system.

Broad Fintech Ltd is a corporation duly organized under the laws of England and Wales under company registration number 11864829 with registered office at WeWork, 123 Buckingham Palace Road, London, United Kingdom, SW1W 9SH.

Broad is willing to provide the services to You only upon the condition that you accept the policies of this Policy as well as the policies of Paynetics AD and Banco Ourinvest S.A. (collectively, the “Financial Partners”). Our Financial Partners take your privacy seriously and compromise to not sell or rent your information to marketers or other third parties in their Privacy Policies. They collect data in order to: comply with applicable law and financial services regulation; verify your identity when you apply to receive a service; operate, improve, protect and develop services provided; mitigate financial loss; or other business purposes. They may retain your data for longer periods than required by law if it is in their legitimate business interests and not prohibited by law.

Broad and the Financial Partners are committed to protecting and respecting your privacy. We will:

• always keep your personal data safe and private
• never sell your personal data

By opening or maintaining a Broad account, you consent, direct and authorize us to share your information with our Financial Partners. The information we share with the Financial Partners under this authorization may include any public or non-public information which we have gathered from or about you when you interact with our services and/or partners, or that we collect via third-party providers and other sources, where permitted by law. This includes information identifying or relating to you (or your devices), relating to your finances, or relating to the services we provide you. This includes information you provide to us or authorize us to obtain about you or in order to obtain financial products or services, and transaction information arising from the services we provide, such as: transactions and transaction history; account balance; sender/recipient of funds’ name, address and financial account information; background check information; digital identity information like metadata, log data and location information; and other relevant data.

You, as the User, are hereby encouraged to read both Financial Partners’ Privacy Policies thoroughly. You can find the policies from Paynetics AD at https://www.paynetics.digital/privacy-and-security-policy/ and from Banco Ourinvest S.A. at https://www.ourinvest.com.br/politica-termos.

The Financial Partners will collect and process your personally identifiable information for the purposes of the services, provided by the Financial Partners, such as account opening and management, card issuance, payment transfers, and other business purposes. The Financial Partners will collect and process the following data from you:

• Full Name
• Personal identification number
• Residential address
• Phone and email
• Nationality/nationalities
• Date of birth
• ID document (National ID card/ passport/ Driving license)
• Real time image/video
• Occupation

Broad will collect your personally identifiable information above for the purpose of performing Know Your Customer policies, for displaying them on the Broad app and for sharing them with processors that require such details to execute their services provided to us. Alongside the Financial Partners, this includes suppliers who provide us with IT, payment and delivery services; card manufacturing, personalisation and delivery companies; and communications services providers.

Moreover, we use your personal data to help with social interactions through our services, or to add extra functions in order to provide a better experience. For example, if you give us permission, we will use the contacts list on your phone so you can easily make payments to your contacts using the Broad app.

Broad securely stores your data in repositories (databases), at secure data centres in public cloud providers (Google Cloud Platform, but not limited to). We take special care to keep data ciphered at rest in the repositories. Also, we segment our database repositories, so data is separated from "personal identifiable data". Broad also keeps your personal data, including personal documents, for as long as you have an account/profile with us. Once you cancel your plan, we will keep this information for up to 5 years. After this period, your data will be deleted from our repositories.

Broad would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request Broad for copies of your personal data.

The right to rectification – You have the right to request that Broad correct any information you believe is inaccurate. You also have the right to request Broad to complete the information you believe is incomplete.

The right to erasure – You have the right to request that Broad erase your personal data, under certain conditions

The right to restrict processing – You have the right to request that Broad restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to Broad’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that Broad transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we will respond to you as soon as possible and considering the legal deadlines.

If you have any questions about our privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us at our email: ola@broad.app.

If we change the way we use your personal data, we’ll update this notice and, if appropriate, let you know by email, through the Broad app or through our website.