Last Modified: April 27, 2022
This policy applies to information Structure Financial ("Structure" or "We") collects from you, the user and data subject ("You") in our Application, our Website and in email, text, and other electronic communications sent through or in connection with this Application (collectively "Services").
The term "Personal Data" as used in this policy, describes information that can be associated with a specific person and can identify that person. Personal Data does not include information that has been aggregated or anonymized so that a specific person can no longer be identified.
This document contains a section dedicated to Brazilian Users and their privacy rights.
Personal Data Controller
A Personal Data controller is a person or organization who controls the collection, holding, processing or use of Personal Data, including a person or organization who instructs another person or organization to collect, hold, process, use, transfer or disclose Personal Data on his or her behalf.
For purposes relevant data protection legislation, Structure is the personal data controller.
Structure Financial Inc. Craigmuir Chambers, Road Town Tortola VG 1110, British Virgin Islands
Structure contact email : [email protected]
Types of Data Collected
The types of Data that this Application collects, by itself or through third parties includes:
- Usage Data which can include your IP address, Uniform Resource Identifier (URI) addresses, your country of origin, the features of the browser or operating system utilized by you, among other identifiers;
- Personal Data, such as: email address; password; first name; last name; your picture, date of birth, physical address, and username;
- Information collected by tracking technologies such as cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting;
- Application information, such as session duration, in-app purchases, application updates, number of sessions, session duration, number of uses, session launches and in-app purchases;
- Device information, such as: device logs, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), universally unique identifier (UUID) your device's operating system, and phone number;
- Your country, geography, and/or region;
- Device permissions such as camera permission and biometric data access permission;
We collect this information from you when you freely provide it on the Application, or in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory may contact us for clarification.
Use of Tracking Tools
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to us.
Method and Basis of Processing Data
Methods of processing
We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. Data may be accessible to you and in some cases, to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. You may request a list of these parties at any time.
Please note, however, that no method of transmission of the Internet or method of electronic storage is 100% secure and we therefore cannot promise, ensure, or warrant the security of any Personal Data that you provide to us.
Legal basis of processing
We may process Personal Data relating to you if one of the following applies:
- You have given your consent for one or more specific purposes. Note: Under some legislations we may be allowed to process Personal Data until you object to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases;
- Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
- Processing is necessary for compliance with a legal obligation to which We are subject;
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
- Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Sharing and Transfer of Data
Structure shares Personal Data in the following ways:
- Affiliates: Structure shares data among Structure affiliates for the purposes described in this Privacy Notice where consistent with applicable legal requirements.
- Third-Party Suppliers: Structure shares Personal Data to trusted third party suppliers to perform services our behalf. These trusted third-parties include, but are not limited to Information Technology Providers, Cloud Providers, Data Hosting Services, and KYC Screening Providers.
- Other Third Parties: Structure discloses certain Personal Data to other third parties:
- Where required by law or legal process (e.g., to tax and social security authorities);
- Where Structure determines it is lawful and appropriate;
- To protect Structure's legal rights (e.g., to defend a litigation suit or under a government investigation or inquiry) or to protect its employees, resources, and workplaces; or
- In an emergency where health or security is at stake.
- Public Security/Law Enforcement: Structure may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
Structure is a global company, with offices and Suppliers located throughout the world. As a result, Personal Data may be transferred outside the country in which you reside for the purposes identified. Any such transfer of Personal Data shall take place under applicable law and will be protected through international data transfer agreements where necessary that have been recognized by relevant data protection authorities as providing an adequate level of protection to the Personal Data we process.
Retention of Data
We will retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. We determine data retention based on the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from an unauthorized user, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.
Personal Data collected for purposes related to the performance of a contract between you and us will be retained until such contract has been fully performed.
Personal Data collected for the purposes of Structure's legitimate interests will be retained as long as needed to fulfill such purposes.
We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, We may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data will be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The Purposes of Processing
The Data we collect about you is collected to:
- Provide the Services and customer support you request;
- Process transactions and send notices about your transactions on the Application;
- Customize and personalize your experience on the Application;
- Create an account for you that links to a third-party account or platform;
- Detect any malicious or fraudulent activity;
- Enable us to monitor and analyze your behavior ("Analytics");
- Beta test certain features or the entire Application;
- Contact you;
- Display content from external platforms;
- Handle productivity related activities;
- Provide social features;
- Provide location-based services;
- Manage contacts and send messages;
- Optimize traffic and performance of the Application;
- Send push notifications to your device;
- Allow us to register you as a user of the services and authenticate your credentials;
- Comply with legal obligations and respond to enforcement requests;
- Protect Structure's rights and interests (or those of our users and third parties);
- Handling productivity related activity;
- Infrastructure monitoring;
- Interaction with external social networks and platforms;
- Location-based interactions;
- Tag management (tags are pieces of code that allow us to better analyze and track activities on the Services); and
- Engage in traffic optimization and distribution.
Device Permissions for Personal Data Access
Depending on your specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by you before the respective information can be accessed. You may still revoke the permission at any time after it has been given. To revoke permissions please refer to your device settings or contact us for support. Revoking of such permissions might impact the proper functioning of the Application. When you grant us permission to use your data, the respective Personal Data may be processed, accessed, modified or removed by the Application.
Our Services are Intended For Adults
Our Application is not intended for children. If you use our Services, you declare yourself to be an adult according to your region's applicable legislation. Minors may use this Application only with assistance of a parent or guardian. Nobody under the age of 13 may use this Application. If you believe we might have any information from or about a child under 13, please contact use at [email protected] or:
Structure Financial Inc. Craigmuir Chambers Road Town Tortola VG 1110 British Virgin Islands
Your Privacy Rights
If you reside in certain jurisdictions, you may be permitted to exercise certain rights regarding your Data that we process. In particular, you may have the right to do the following:
- The right to object to the processing of your Data. We will no longer process your Data once you object or withhold consent to our processing of your Data so long as processing the Data is not necessary for the performance of or in relation to a contract or service to which you are a party. We may still collect and process your Data as a result of a legal obligation.
- The right to access your information. Upon demand, we may provide you with the contents of your Data that we process, our sources from which the Data was gathered from, the manner in which such Data was processed, the reason for the disclosure of your Data to recipients (if any), information where an automate process was utilized as the sole basis for any decision that significantly affects or will affect you, and the date when your Data was last accessed and modified.
- The right to correct your information. You have the right to dispute any inaccuracy or error in your Data.
- The right to delete your information. In select circumstances, you have the right to suspend, withdraw or order the blocking, removal or destruction of your Data from our systems. For example, you may request that your information be deleted if you find your Data was not being used for the purpose you authorized us to use it or if your rights as a data subject were violated by us or a Data processor.
- The right to damages. In the event your rights as a data subject are violated, you will be indemnified for any damages sustained due to any inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your personal data.
- The right to withdraw your consent at any time. You have the right to withdraw consent where you have previously given it for the processing of your Personal Data.
- The right to receive your Data and have it transferred to another controller. You have the right to receive your Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means or based on your consent or contract for a commercial purpose.
- The right to lodge a complaint. You have the right to bring a claim before a competent data protection authority.
If you would like to exercise any of the rights listed above, or if you would like to contact us about any questions you may have regarding your Personal Information, please contact us at [email protected] and provide (a) enough information to identify you and (b) a description of what right you want to exercise and the information to which your request relates. Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
How "Do Not Track" Requests Are Handled
Our Application does not support "Do Not Track" requests.
Information for Users Residing in Brazil
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymized personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, please see "Types of Data Collected" above.
Why we process your personal information
To find out why we process your personal information, please see "Legal Basis of Processing" above.
Your Brazilian privacy rights, how to file a request and our response to your requests
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests. Should it be impossible for us to do so, we'll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you'd like your personal information to be delivered in electronic or printed form. You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorized by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Additional information for Users residing in Brazil
We can transfer your personal information outside of the Brazilian territory, if the destination country, or the international organization which receives the personal information, provides an adequate level of protection of the personal information according to the ANPD. The ANPD authorizes such transfers whenever it considers that country to possess and provide personal information protection standards comparable to those set forth by the LGPD, having taken into account the following:
- the general and sectoral rules of the legislation in force in the country of destination or in the international organization;
- the nature of the personal information subject to the transfer;
- the compliance with the general principles on the protection of the personal information and on the rights of the individuals as set forth in the LGPD;
- the adoption of suitable security measures;
- the existence of judicial and institutional guarantees for the respect of personal information protection rights; and
- any other pertinent circumstance related to the relevant transfer.