Privacy Policy

For you to understand better what we do with your information

We have done our best to explain clearly and simply what personal data we will need from you and what we are going to do with each of them. Therefore, we have separated the most important points below.

‍In addition, we are always available to answer any questions you may have at friends@husky.io and through the chat available on our website and in our application (“app”).

‍A)   To ensure the security of your personal data, we use an SSL security certificate and third-party servers from AWS, Linode, Intercom, MailChimp, and Pipedrive. With this, these companies have access to your personal data, only to store them, as soon as you provide them on the website/app or in other means of contact with us. If you have any problems with this, we ask that you do not enter your information in any form on the site, as we will not be able to store it otherwise.

‍B)   When you fill out any form on our website/app, we may ask you for the following personal data: name, CPF/CNPJ, digital/electronic signature in your own hand, personal document with photo, proof of address, e-mail and cell phone.

‍C)   When you enter our website/app, cookies are automatically placed on your browser, using the Google Analytics software from Intercom, Facebook, and Pipedrive, with which we collect the following data from you: IP (Internet Protocol) number, location, referring source, browser type, duration of visit and pages visited. This information is obtained without you having to fill out forms and we collect it because we have an obligation defined by law to store your access logs for 06 (six) months. Plus, it helps us make your experience better and more personalized.

‍D)   We will also store all the conversations you have with us, by email, phone and even through Intercom, a tool that is used to guarantee live chat on our website/app, as this will improve your service and make it more efficient. Without this history, probably every time you use the site you would have to repeat what you have already given us before.

‍E)   All your data is processed for specific purposes and in accordance with the Personal Data Protection Law (Law nº 13.709/2018). All this information is described in a table, to facilitate its visualization, in our Privacy Policies.

‍F)   Even if you have already provided us with your personal data, you have the full right to, at any time: confirm that your data is being processed; access your data; correct your data; anonymize the data; block or eliminate unnecessary, excessive or processed data in violation of the Law; request data portability to another provider; delete data, except those required by law or by Circular/Resolution of the Central Bank of Brazil; obtain information about who Husky has made shared use of data; obtain information about the possibility of not providing consent and about the consequences of denial; and go back and revoke your consent.

‍G)  Our Privacy Policy may change, but you can always access the most up-to-date version on our website. Also, if we are going to take any action that the law requires your authorization, you will receive prior notice so that you can accept or decline.

‍H)   The Privacy Policy below is divided as follows to facilitate your access to information:

     1. Availability Date;
     2. Explanation of Technical Terms or in Foreign Language;
     3. User Privacy and Third-Party Data Operators;
     4. Collection of Personal Data;
     5. Purposes and Legal Basis for the Processing of Personal Data;
     6. Sharing of Users' Personal Data;
     7. Deletion of Personal Data of Site Users;
     8. User Rights and Personal Data Owner;
     9. Security;
     10. Changes to the Privacy Policy;
     11. General Provisions and Data Officer;

‍Before you create your account on the Husky website/app, it is important that you read, understand, and freely, unequivocally, and informed acceptance of this Privacy Policy.

The website/app called “HUSKY”, whose domain is www.husky.io and the app download is available in the app stores for Android and iOS, is owned, maintained, and controlled by HUSKY INSTITUIÇÃO DE PAGAMENTO LTDA., a legal entity incorporated in the form of limited liability company, registered with the CNPJ under nº 35.486.142/0001-95, registered in Brazil, headquartered at Avenida das Nações Unidas, nº 12.901, Bloco A, Edifício Norte, Sala 12.103 X, Bairro Brooklin Paulista, São Paulo - SP, CEP: 04578-910.

This document aims to provide information on the collection and processing of personal data provided by Users and is in compliance with Law nº 12.965/2014 (Marco Civil da Internet) and with Law nº 13.709/2018 (General Personal Data Protection Law).


1. DATE OF AVAILABILITY OF THE TEXT

This document was made available on January 6, 2022.

‍2. EXPLANATION OF TECHNICAL TERMS OR IN FOREIGN LANGUAGE

‍Below are the meanings of technical nomenclatures and terms in the English language.

API: Application Programming Interface is understood as a set of programming routines and patterns for accessing a software application or web-based platform.

Chat Online: A form of communication at a distance, using computers connected to the internet, in which what is typed on the keyboard of one of them appears in real-time on the screen of all participants in the chat.

Cookies: Small text files that are recorded on the Internet user's computer and can be retrieved by the website that sent them during navigation. They are primarily used to identify and store information about visitors.

Cryptography: A set of principles and techniques to encrypt the writing, making it unintelligible to those who do not have access to the agreed conventions.

Download: File transfer from a given server to the User's computer.

E-mail: Method that allows composing, sending, and receiving messages through electronic communication systems. It is also the expression that identifies the electronic address of a User in a computer network, allowing the sending and receiving of messages.

IP (ou Internet Protocol): Unique identification for each computer connected to a network.

Link: Link between documents on the Internet.

Newsletter: Type of newsletter, regularly distributed to subscribers and generally covering a certain topic. They are usually sent by email, which can be received after registering on a website.

Site: Internet location identified by a domain name, consisting of one or more hypertext pages, which may contain text, graphics, and multimedia information.

Transport Layer Security (TLS)/Https: Acronym of Hyper Text Transfer Protocol Secure, which means Secure Hypertext Transfer Protocol. It is a communication protocol used for hypermedia information systems, being the basis for data communication on the World Wide Web (www).

Vírus: Software malicious software that infects systems and computers, with the aim of causing damage, makes copies of itself and tries to spread itself to other computers, using various means.

‍3. USER PRIVACY AND THIRD-PARTY DATA OPERATORS

‍3.1. Protecting your privacy is very important to us and, as we are a technology-based company, some of our services and functionalities end up being outsourced to other data operators to guarantee excellence and security in these services.

3.2. The information trafficked on the site, including registration on pages and offers on our site/app, is stored and encrypted by the independent platform Pipedrive and Intercom (we recommend that you read Pipedrive's terms of use and privacy policies, and the terms of Intercom's use and privacy policy as these documents are unrelated to our Privacy Policy).

3.3. Other information that we ask for when filling out forms, such as in our chat and possible newsletter subscription, will be stored on the operator MailChimp, Intercom, Linode, and AWS, which are also independent servers.

3.4. We use Intercom as your way of communicating with us. All conversations are stored on Intercom's independent servers for the purpose of making responses possible for you and other contacts (we recommend that you read Intercom's terms of use and privacy policies, as these documents have no relation to our Policy of Privacy).

3.5. The servers used by Husky that are able to ensure the security of your data are located outside Brazil, but continue in countries that provide an adequate degree of protection of personal data, according to article 33, I of the Law n. 13.709/18.

3.6. In addition, the site has a security certificate Transport Layer Security (TLS)/https. Therefore, when transmitting information you should always ensure that your browser is able to validate this certificate.

‍3.7. All-access logs, set of information regarding transactions, date and time of use of a given internet application from a given IP address, will be kept by Husky, confidentially, in a controlled and secure environment of AWS, Intercom, Pipedrive, and MailChimp, for a minimum period of 6 (six) months, by order of Law n. 12.965/2014.

‍4. COLLECTION OF PERSONAL DATA

‍4.1. Information freely provided by Users: Husky directly requests the following personal data: name, CPF, personal document with photo, address, handwritten digital/electronic signature, e-mail, and cell phone.

4.2. Information we collect indirectly: The website/app collects personal data indirectly, through cookies placed in your browser using the Google Analytics, Intercom, MailChimp, Pipedrive, and Facebook software, in order to improve your experience as a User and fulfill obligations cool. Information is collected, such as: IP address, referral source, browser type, duration of visit and pages visited.

4.3. History of your use of the website and app: Husky stores information regarding all interactions that have already taken place between you and our system through our apps, such as chat messages, email exchanges, international payments/shipments, and file uploads. Such data is stored in order to have a history about you and, therefore, facilitate communication, resolve queries more effectively and make your experience as a User on the website/app more personalized.

‍5. PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

‍5.1. HUSKY may use Users' personal data for the purposes that will be presented below:

Personal data type
Name
CPF
Personal document with photo
E-mail
Cell phone
Digital/electronic signature/by hand
Address
IP (Internet Protocol), Location, reference source, browser type, duration of visit, Pages visited
Conversation history
Legal base
Necessary for the execution of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Article 7, V, Law nº 13.709/2018).
Necessary for the execution of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Article 7, V, Law nº 13.709/2018).
Compliance with a legal or regulatory obligation by the controller (Article 7, II, Law nº 13.709/2018).
Necessary for the execution of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Article 7, V, Law nº 13.709/2018).
Necessary for the execution of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Article 7, V, Law nº 13.709/2018).
Compliance with a legal or regulatory obligation by the controller (Article 7, II, Law nº 13.709/2018).
Necessary to meet the legitimate interests of the controller or a third party (Article 7, IX, Law nº 13.709/2018).
Compliance with a legal or regulatory obligation by the controller (Article 7, II, Law nº 13.709/2018).
Necessary to meet the legitimate interests of the controller or a third party (Article 7, IX, Law nº 13.709/2018).
Motivation
User ID. This is essential personal data for us to be able to contact you, meet your requests, and provide you with targeted responses, in addition to respecting the rules of the Central Bank and Banking Partners.
User ID. This is essential personal data for us to be able to contact you, to meet your requests and provide you with targeted responses, in addition to respecting the rules of the Central Bank of Brazil and Comercial (Banks) Partners.
Compliance with the Circulars and Resolutions of the Central Bank of Brazil regarding Exchange Contracts and relationship with banking partners, which imposes Husky's duty to ensure that information provided by the customer is true.
User ID. This is essential personal data for us to be able to contact you, to meet your requests and provide you with targeted responses, in addition to respecting the rules of the Central Bank of Brazil and Comercial (Banks) Partners.
Means of communication with you, to meet your requests and provide targeted responses, in addition to respecting the legal rules of the Central Bank and Banking Partners.Marketing, promotions, and news about our services and products, base segmentation, and content that allows us to maintain our relationship with you. In this specific case, we keep in the email sent an option for you to select to stop communication for this purpose at any time.
Compliance with article 15 of Law n. 12.965/2014, which imposes Husky's duty to keep the respective records of access to internet applications, under secrecy, in a controlled and secure environment, for a period of 6 (six) months.
Creation of a history about you, ease of communication, greater effectiveness in resolving questions, and improving your experience as a User on the Husky website/app.
Compliance with article 15 of Law n. 12.965/2014, which imposes Husky's duty to keep the respective records of access to internet applications, under secrecy, in a controlled and secure environment, for a period of 6 (six) months.
Creation of a history about you, ease of communication, greater effectiveness in resolving questions, and improving your experience as a User on the Husky website/app.

6. SHARING USER'S PERSONAL DATA

‍6.1. Only professionals from the Husky team will be able to have access to your personal data and those of other Users, given that our team manages and monitors the website/app, in addition to responding to your requests and those of other Users and contacting you in an active.

‍6.2. In addition, data operators AWS, Linode, Intercom, Pipedrive, and MailChimp may have access to personal data, as such information is stored on their servers. It is clarified that such operators are not authorized to carry out any type of individualized treatment or autonomously, other than storage.

‍7. DELETION OF PERSONAL DATA OF SITE USERS

‍If you no longer wish to use Husky's services, after the intended purpose of the processing of personal data has been achieved or upon your request as a User, you may request by email to friends@husky.io and all your personal data will not be required by legal determination or resolution/circular of the Central Bank of Brazil, will be deleted immediately and permanently from the website/app, except for access logs (set of information regarding the date and time of use of a particular internet application from a certain IP address), which will be kept confidential, in a controlled and secure environment, for a period of 6 (six) months, pursuant to Law no. 12.965/2014.

‍8. USER RIGHTS AND PERSONAL DATA OWNER

‍8.1. You as the holder of personal data (User) have the right to obtain from Husky, relation to the data processed by us, at any time and upon request in the email friends@husky.io:

8.1.1. Confirmation of the existence of data processing;

8.1.2. Access to data;

8.1.3. Correction of incomplete, inaccurate, or outdated data;

8.1.4. Anonymization, blocking, or elimination of unnecessary, excessive, or processed data in violation of the provisions of Law nº 13.709/2018;

8.1.5. Data portability to another service or product provider, upon express request and observing commercial and industrial secrets;

8.1.6. Deletion of personal data processed with the consent of the holder, except in the cases provided for in Law nº 13.709/2018;

8.1.7. Information from public and private entities with which Husky has shared data use;

8.1.8. Information about the possibility of not providing consent and about the consequences of denial;

8.1.9. Revocation of Consent.

9. SECURITY

‍Husky is committed to preserving the stability, security and functionality of the website, through technical measures compatible with international standards and by encouraging the use of good practices. However, no website available on the internet has a full guarantee against illegal invasions. In cases where unauthorized third parties unlawfully invade the system, Husky will make every effort to prevent harm to you and any other User and locate the violators, but is not responsible for the damages caused by them.

10. CHANGES IN THE PRIVACY POLICY

‍10.1. Husky may unilaterally add and/or modify any clause contained in this Privacy Policy. The updated version will be valid for the use of the platform carried out from its publication. The continuity of access or use of the site, after disclosure, will confirm the validity of the new Privacy Policy by you and any other User.

10.2. If the change made requires your consent, you will be presented with the option of freely, unequivocally, and informed acceptance of the new text or of rejecting it.

10.3. If you or any other User does not agree with the change, you may not provide consent for specific acts, having service limitations for such alternative, or you may completely terminate your relationship with Husky. Such termination will not, however, exempt you or any other User from complying with all obligations assumed under the preceding versions of the Privacy Policy.

‍11. CONTACT
‍11.1. After reading this Privacy Policy, if you still have questions about the treatment of your personal data, you can contact us by email.privacy@husky.io.  If you prefer, you can also get in touch via the website/app chat, available in the lower right corner, where you will need to fill in the form with personal contact details.

11.2. Husky has a specific text to regulate the rights, duties, guarantees, and general provisions: the Terms of Use and Conditions. All these documents are inseparably part of this Privacy Policy.