Privacy Policy

ClickCard, Inc., a Delaware C Corporation (EIN 92-3620829), headquartered at 651 N Broad St, Suite 206, Middletown, DE 19709 ("ClickCard," "we," "our," or "us"), values your privacy and is committed to protecting your personal information in accordance with applicable U.S. laws.

How important is this policy?
Your data is important. From the moment you trust our company with your information, we treat it with the greatest security and confidentiality. Here you will find the main rules we have for the protection of your information.

Important to say that this privacy policy informs you about your rights and how you can exercise them.

1. Who is Covered?

This Policy applies to:

1. ClickCard employees, service providers, and partners;
2. Users of the ClickCard platform and app;
3. Visitors to our websites, events, and physical premises;
4. Clients, suppliers, and third parties in general who have any relationship with ClickCard.

2. Privacy Contact

Questions, requests, suggestions, or complaints related to privacy and data processing can be directed to:

Gustavo Andrade – Data Protection Officer (DPO)
Email: [email protected]

3. What Data We Collect and for what Purposes

We collects personal data transparently, ethically, and limited to specific purposes. The data may include, but is not limited to:

• Registration data: name, email, phone number, job title, business address, social media profiles, company ID.
• Location data: only with express authorization.
• Platform access data: login, password, usage records, cookies, and digital identifiers.
• Professional data: information entered on digital cards, contracts, service orders.
• Financial and banking data: exclusively for payment purposes.

Purposes:

• Provision of ClickCard’s services;
• Execution of contracts;
• Compliance with legal and regulatory obligations;
• Institutional, administrative, or marketing communication (with consent);
• Information security, fraud prevention, and risk management.

4. Legal Bases for Data Processing

Data is processed based on:

• Consent from the data subject, when applicable;
• Execution of a contract or preliminary procedures;
• Compliance with legal or regulatory obligations;
• Regular exercise of rights in judicial, administrative, or arbitration proceedings;
• ClickCard’s legitimate interest, respecting balance with the data subject’s rights and freedoms.

5. Data Subject's Rights

In accordance with the LGPD and U.S. Law, we guarantee the following rights to data subjects:

• Confirmation of the existence of processing;
• Access to data;
• Correction of incomplete, inaccurate, or outdated data;
• Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
• Data portability, when applicable;
• Deletion of personal data processed with consent, except as provided by law;
• Information about sharing and the entities with whom the data is shared;
• Revocation of consent.

Requests can be made directly through the ClickCard platform or by sending an email to [email protected].

6. Data Sharing

ClickCard may share personal data:

• With essential service providers (hosting, cloud, information security);
• With public authorities, under court order or legal obligation;
• In corporate operations (merger, acquisition, restructuring), ensuring the rights of the data subjects;
• Always observing principles of necessity, adequacy, and security.

7. International Data Transfer and Information Security

When international data transfer occurs, ClickCard will ensure compliance with legal requirements, observing adequate protection standards as provided by the U.S. and LGPD.

We maintain appropriate technical and administrative measures to protect personal data:

• Access control and authentication;
• Encryption and anonymization, when applicable;
• Security monitoring and auditing;
• Internal governance and compliance policies.

Users are responsible for keeping their password confidential and secure.

8. Data Retention and Deletion

Data will be retained:

• For the time necessary to fulfill the purposes described in this Policy;
• While there are pending legal or contractual obligations;
• For up to 6 months of inactivity, after which they may be deleted.

Definitive deletion may be requested at any time, except in cases provided by law.

9. Use of Cookies and Similar Technologies

We use cookies to:

• Personalize the user experience;
• Analyze performance and traffic;
• Display advertising, including personalized ads.

You can manage your cookie preferences in your browser settings.

10. Changes to this Policy

ClickCard may update this Policy at any time, always publishing the latest version on its website and notifying data subjects by email in case of significant changes.

11. Mitigation Measures and Incidents

We continuously invest in risk mitigation processes and security incident prevention. If any event occurs that compromises personal data, we will notify data subjects and authorities as required by U.S. law.

12. General Provisions

By accessing or using ClickCard’s services, you acknowledge and agree to the terms of this Privacy Policy. For more information, contact us at [email protected].