Privacy Policy
Effective as of its publication
English version provided for convenience. In case of divergence, the Portuguese version prevails.
1. Introduction and Data Controller
This Privacy Policy describes how ANITEC TECNOLOGIA EM SISTEMAS DE INFORMAÇÕES LTDA ("VerticoSys", "we"), a private legal entity registered under CNPJ No. 41.522.323/0001-22, headquartered at Av. Brig. Faria Lima, 1811, São Paulo/SP, Brazil, collects, uses, stores, shares and protects the personal data processed within the VerticoSys platform, as Controller, pursuant to Law No. 13,709/2018 (Brazilian General Data Protection Law – LGPD).
This Policy applies to the personal data of legal representatives, operating users, employees of Contracting Companies (in the payroll context) and other individuals whose data is processed as a result of providing the Services.
2. Data Collected
In providing the Services, VerticoSys may collect the following categories of data:
| Category | Data examples | Primary purpose |
|---|---|---|
| Company registration data | Legal name, tax ID, address, bank details | Account enablement and provision of the Services |
| Operating user data | Name, work email, role, phone number | Access control and permission profiles |
| Identification data (KYC/AML) | Identity documents, corporate records | Anti-money laundering and regulatory compliance |
| Financial and transactional data | Statements, balances, transaction history, currencies used | Execution of financial operations and reconciliation |
| Platform usage data | Access logs, IP address, device, cookies | Security, audit and product improvement |
| Payroll data | Name, tax ID and bank details of the Contracting Company’s employees | Execution of mass payments/domestic payroll |
3. Purposes of Processing
The personal data collected is processed for the following purposes:
- Enable registration, authentication and access management on the platform;
- Perform the contracted features, including multi-currency financial management, transfers, reconciliation and domestic payroll automation;
- Comply with legal and regulatory obligations, including anti-money laundering and counter-terrorism financing procedures (AML) required by the Financial Rails Partners;
- Ensure information security, prevent fraud and carry out internal audits;
- Provide technical support and communicate with Users about platform operations;
- Improve the Services through statistical and usage analysis, preferably in aggregated and anonymized form.
4. Legal Basis for Processing
VerticoSys’s processing of personal data is based, as applicable, on the following legal bases set out in article 7 of the LGPD:
- Performance of a contract or of preliminary procedures related to a contract to which the data subject is a party;
- Compliance with a legal or regulatory obligation by the controller, including AML rules and FX and payment regulations;
- Legitimate interest of VerticoSys, observing the fundamental rights and freedoms of data subjects, for security and fraud prevention purposes;
- Consent of the data subject, where applicable, especially for purposes not essential to providing the Services.
5. Data Sharing with Partners
To enable the execution of the financial operations offered on the platform, certain data may be shared with the Financial Rails Partners (including Gates2B and GlobalDEX), banking institutions and other infrastructure providers necessary for transaction settlement, PIX, FX and payment processing.
Data may also be shared with technology service providers contracted by VerticoSys to operate the platform, including cloud infrastructure services (storage and cryptographic key management), always under contractual obligations of confidentiality and information security.
VerticoSys may also share personal data when required by law, court order or determination of a competent regulatory or supervisory authority.
6. International Data Transfers
Due to the multi-entity and multi-currency nature of the platform, and possible integration with FX partners and international banking correspondents, personal data may be transferred to other countries, including in the context of international remittance features when effectively activated. In such cases, VerticoSys will adopt the safeguards required by the LGPD, seeking to ensure that the recipient country or organization provides an adequate level of data protection, or by adopting specific contractual data protection clauses.
7. Storage and Information Security
Personal data is stored in cloud infrastructure with technical and administrative security controls, including encryption of data at rest and in transit and access key management. VerticoSys adopts reasonable technical and organizational measures to protect data against unauthorized access, loss, alteration or improper disclosure.
Notwithstanding these efforts, no system is entirely immune to security incidents. In the event of an incident that may pose a relevant risk to data subjects, VerticoSys will notify the affected data subjects and the Brazilian National Data Protection Authority (ANPD), as required by applicable legislation.
8. Data Retention
Personal data will be retained for the period necessary to fulfill the purposes for which it was collected, observing the retention periods required by legal, regulatory, tax and anti-money laundering obligations, even after the end of the contractual relationship with the Contracting Company.
9. Data Subject Rights
Pursuant to article 18 of the LGPD, the data subject may, upon request, exercise the following rights:
- Confirmation of the existence of processing of their data;
- Access to the personal data processed;
- Correction of incomplete, inaccurate or outdated data;
- Anonymization, blocking or deletion of unnecessary or excessive data, or data processed in breach of the law;
- Data portability to another service provider, observing commercial and industrial secrecy;
- Deletion of data processed based on consent, except in cases of legal retention;
- Information about the public and private entities with which the data has been shared;
- Withdrawal of consent, where this is the applicable legal basis.
Requests may be submitted through the contact channels indicated in Section 14 of this Policy and will be answered within the legally established timeframes.
10. Cookies and Tracking Technologies
The platform may use cookies and similar technologies to enable essential features, maintain authenticated sessions, ensure security and obtain aggregated usage metrics. Users may manage preferences for non-essential cookies through their browser settings, noting that disabling certain cookies may affect platform functionality.
11. Processing of Minors’ Data
The VerticoSys platform is intended exclusively for business (B2B) use by legal entities and their representatives and employees over 18 years of age, and is not directed at minors. Any data of minors processed in the payroll context (e.g. dependents) will be processed exclusively for the corresponding legal purposes.
12. Data Protection Officer (DPO)
ANITEC TECNOLOGIA EM SISTEMAS DE INFORMAÇÕES LTDA will provide a specific channel for contacting the Data Protection Officer (DPO), to be indicated on the platform and/or through official service channels, for receiving communications from the ANPD and requests from data subjects.
13. Changes to this Policy
This Privacy Policy may be updated periodically to reflect legislative or regulatory changes or platform developments. Material changes will be communicated to Users with reasonable advance notice, and periodic review of this document is recommended.
14. Contact
Questions, requests or complaints related to the processing of personal data may be sent to ANITEC TECNOLOGIA EM SISTEMAS DE INFORMAÇÕES LTDA, CNPJ 41.522.323/0001-22, headquartered at Av. Brig. Faria Lima, 1811, São Paulo/SP, Brazil, by phone at +55 (43) 9934-0064.