This Policy explains what personal data Coinsafe collects, what it uses it for, who it shares it with and how you can exercise your rights, in accordance with Brazil's General Data Protection Law (Lei Geral de Proteção de Dados, Law No. 13,709/2018, "LGPD").
1. Who is responsible for your data
1.1. The data controller is COINSAFE CAPITAL LTDA, CNPJ (Brazilian company taxpayer ID) 63.632.720/0001-90, with its registered office at Rua Moritz Germano Hoffmann, 66, 2º andar, Sala 202, Box 380, Centro I, Brusque/SC, CEP 88350-180.
1.2. Data protection officer (encarregado): Hui Jie Cinzia Wu. Contact: suporte (arroba) coinsafe.com.br, with the subject line "Privacidade".
2. This website
2.1. The coinsafe.com.br website is informational. It has no forms and does not use cookies or tracking tools.
2.2. As with any website, the hosting server may log technical access data, such as IP address, date and time, and browser type, for security and operation.
2.3. The "Sign up" and "Log in" buttons lead to the Coinsafe platform, where the rules below apply.
3. Data we collect on the platform
- Individual sign-up: name, CPF (Brazilian individual taxpayer ID), date of birth, identity document, address, email, phone or WhatsApp and, when needed, a photo to confirm identity.
- Company sign-up: legal name, CNPJ, corporate documents, business email, phone, and personal data of partners, officers, representatives and ultimate beneficial owners.
- Financial and trade data: registered bank accounts, wallet addresses, quotes, acceptances, payments, transfers, stated purpose and trade history.
- Compliance data: information on source of funds, occupation or business activity, estimated net worth and revenue, and results of checks against public and sanctions lists.
- Usage and security data: access logs, IP, device, login date and time, and actions taken on the platform.
4. What we use it for and on what legal basis
- Opening and maintaining your account and executing trades: performance of a contract (art. 7, V, LGPD).
- Verifying identity, preventing money laundering and fraud, and providing information to authorities: compliance with legal and regulatory obligations (art. 7, II) and, for sensitive data such as biometrics, fraud prevention and the security of the data subject (art. 11, II, g).
- Platform security and access logs: compliance with a legal obligation (Marco Civil da Internet, Brazil's Internet Civil Framework) and legitimate interest (art. 7, IX).
- Support and communications about your account: performance of a contract.
- Defense in legal proceedings: regular exercise of rights (art. 7, VI).
4.1. Coinsafe does not sell personal data and does not use your data for third-party advertising.
5. Who we share it with
- The Central Bank of Brazil (Banco Central do Brasil), COAF (Brazil's Financial Intelligence Unit), the Receita Federal (Brazil's Federal Revenue Service) and other authorities, when required by law or by an order.
- Banks and payment institutions involved in settlements in reais.
- Identity verification, fraud prevention and risk analysis companies.
- Technology, hosting, cloud and email providers, which process data on Coinsafe's behalf and under confidentiality agreements.
- Legal and accounting advisors, when necessary.
6. Transfers outside Brazil
6.1. Some technology providers may store or process data outside Brazil. In these cases Coinsafe adopts the safeguards provided for in articles 33 to 36 of the LGPD, such as contractual clauses.
6.2. Blockchain records, such as wallet addresses and transactions, are public by nature and accessible from any country.
7. How long we keep it
7.1. Data is kept while the account is active and, after closure, for the periods required by law. Registration and trade data is kept for at least 5 years after the end of the relationship or the trade, as required by anti-money laundering legislation, or for 10 years when required by Central Bank regulations.
7.2. Access logs are kept for at least 6 months, as required by the Marco Civil da Internet.
8. Your rights
8.1. You may request, at any time: confirmation that we process your data; access; correction of incomplete or outdated data; anonymization, blocking or deletion of unnecessary data; portability; information about sharing; review of automated decisions; and objection to processing carried out in breach of the law. Complete confirmation and access requests are answered within 15 days.
8.2. Some requests may be limited where retention of the data is required by law or by a regulator, for example under anti-money laundering rules. In those cases we will explain the reason.
8.3. To exercise your rights, write to suporte (arroba) coinsafe.com.br. You may also file a complaint with the ANPD (Autoridade Nacional de Proteção de Dados, Brazil's National Data Protection Authority).
9. Security
9.1. Coinsafe uses an encrypted connection, role-based access control, two-factor authentication and activity logging to protect data.
9.2. If a security incident poses a significant risk to data subjects, Coinsafe will notify the ANPD and those affected, as required by law.
10. Cookies
10.1. This website does not use cookies. The platform uses only the cookies and local storage needed to keep you logged in and protect your session.
11. Minors
11.1. Coinsafe's services are not intended for anyone under 18, and we do not knowingly collect data from minors.
12. Changes to this Policy
12.1. This Policy may be updated. The date of the current version appears at the top of the page, and significant changes will be communicated to Clients through the official channels.
