Privacy Policy

Introduction and Overview:

This Privacy Policy ("Policy") explains how Basemaker Soluções de Performance Digital Ltda. (“Basemaker,” “Company,” or “We”) handles your personal information (collectively, “Personal Data”) when you use or access this digital platform (“Platform”). The Policy also describes your rights regarding your Personal Data and explains how to contact us to learn more about our data practices or to exercise your rights. For the purposes of this Policy, “Users” are all those who, in any way, use or visit the Basemaker Platform.

This Policy explains, in a simple, direct, and transparent manner, which Personal Data is collected and processed by Basemaker and for what purposes, as well as indicating with whom it may be shared and which tools are available for you to manage your Personal Data. We do not collect more Personal Data than is strictly necessary for the execution of our activities.
For the purposes of processing Users’ Personal Data under this Policy, Basemaker is the data controller of those who visit or register on our Platform, whether the registration is carried out directly by an individual or as a representative of a legal entity, in accordance with the Brazilian General Data Protection Law – Law No. 13.709/2018 (“LGPD”).

PLEASE NOTE THAT WE RECOMMEND THIS POLICY BE READ CAREFULLY. IT DESCRIBES HOW YOUR PERSONAL DATA IS PROCESSED WHEN YOU: (I) USE OUR PLATFORM; (II) CONTACT US; (III) USE OUR SERVICES; OR (IV) HAVE YOUR PERSONAL DATA PROCESSED IN ANY WAY BY THE PLATFORM.

As described in this Policy, it is possible to register on our Platform either as an advertiser (“Advertiser”) or as a digital content creator (“Creator”). Please read our [Terms and Conditions for Advertisers, if you intend to use our Platform as an Advertiser] or our [Terms and Conditions for Creators, if you intend to use our Platform as a Creator]. If you do not agree with this Policy or with the respective Terms and Conditions of the Advertiser or the Creator, as applicable, please do not access or use our Platform.

Policy Modifications: We inform you that Basemaker may change this Policy from time to time, in order to reflect changes in the processing of Users’ Personal Data. If we make changes, we will update the effective date or the last modification date at the top of this Policy.

If, after reading this Policy, you still have any questions or, for any reason, need to contact us regarding matters involving your Personal Data, you may reach us at the following email: Data Protection Officer: privacidade@basemaker.co. If you do not agree with the updated version of this Policy, please discontinue the use of our Platform.

1. Who We Are

Basemaker, headquartered in the City of Itajaí, State of Santa Catarina, at Rua Israel de Almeida, nº 1424, house 01, ZIP Code 88.312-050, registered with CNPJ/ME under nº 49.001.164/0001-22, is a technology platform available at https://www.basemaker.co. It was created and developed to provide an environment where Creators can find advertising opportunities from Advertisers for their profiles and social media pages (“Profiles”), and Advertisers can run targeted ads on Creators’ Profiles in order to increase the performance of digital campaigns ("Services”). We emphasize that Advertisers will never have access to personal data or any other information about followers or users of Creators’ social media accounts. There is no sharing of personal data between Creators and Advertisers.

The Platform allows Creators to provide anonymized data about audience engagement and interests, such as demographic information, interests, consumer behaviors, and preferences. Neither Creators nor the Platform provide personal data to Advertisers. Based on this anonymized engagement data, Advertisers can choose which audiences they want to reach and thus create more relevant and personalized advertising campaigns, without ever accessing any user or follower data.

2. What Personal Data We Collect and Process:

Basemaker only receives or otherwise collects the following types of information related to Users: (1) registration information, either as an Advertiser or Creator, to use the Platform; (2) financial information; (3) information about visitors or Users of our Platform; and (4) information for communications and support.

By choosing to proceed with your registration on our Platform, you declare that all information provided is true, complete, and up-to-date, and that you are responsible for updating it as necessary.

2.1. Registration Information. When a User registers, either on their own behalf or as a representative of a legal entity, for [pre-registration and registration] on the Platform, and when you complete or update your registration on our Platform, we request certain information to verify your identity and enable the creation and maintenance of an account. The Personal Data collected during pre-registration and registration will depend on the type of access the User will have on the Platform: (a) as an Advertiser; or (b) as a Creator.

a) Advertiser

• full name;
• CPF (Brazilian Tax ID);
• RG (Brazilian ID number);
• email address;
• date of birth;
• phone number;
• address;
• profession;
• company;
• job title;

b) Creator

• full name;
• CPF number (Brazilian Tax ID);
• RG number (Brazilian ID number);
• date of birth;
• copy of an identity document;
• social media username;
• potential information about the social media Profile, such as number of followers, engagement rates, and other available data;
• email address;
• phone number;
• address;
• profession;
• preferred contact method;
• optional profile picture; and

Optionally, the Creator may provide income data for profile analysis.

When the Creator logs into the Platform via social media, such as Facebook, Instagram, or Twitter, the Platform may request marketing and advertising permissions to access Profile information, according to the terms of use and privacy policies of each platform/social network. This information may include demographic data such as age, gender, geographic location, interests, and consumer behaviors, as well as information about the user’s activities and interactions on the social network, such as likes, shares, and comments.

2.2. Financial Information. If the User registers on the Platform as an Advertiser, we may collect the following financial and transactional data:

• full name;
• payment or deposit method details;
• billing address.

2.3. Browsing and Device Information. Basemaker collects, during access to the Platform—even if the User is not registered or logged in—the information listed below:

• technical data, such as URL information;
• cookie data;
• your IP address;
• browser type;
• information about the mobile device or computer;
• browser language;
• date and time of the request;
• type of network connection;
• information enabling digital rights management;
• operating system;
• geolocation data;
• pages visited on the Platform;
• duration of visit on the Platform and navigation paths within the Platform.

2.4. Communications and Support. If the User contacts Basemaker for any reason—such as obtaining support, giving feedback, submitting suggestions, or reporting a problem or question (whether or not they have created an account)—the following User contact information, as well as messages and other related data, are collected and stored:

• full name;
• email address;
• messages.

3. Why We Collect and Process This Personal Data

The following list details the Personal Data we collect and explains their respective purposes:

a) Registration Data – Advertiser or Creator

• Perform the User’s pre-registration and registration on the Platform, either as an Advertiser or Creator; grant the User access to the Platform, either as an Advertiser or Creator;
• Manage the User’s account on the Platform, either as an Advertiser or Creator; provide our Services; verify your identity;
• Conduct research and analysis; comply with legal and/or regulatory requirements;
• Respond to questions and concerns;
• Provide User support, either as an Advertiser or Creator;
• Contact the User (by email, mail, text messages, and/or phone) regarding various matters, including the use of the Platform and/or to conduct satisfaction surveys;
• Send messages with information and offers about products or services that may be of interest; develop engagement initiatives;
• Conduct advertising and marketing; and generate knowledge, innovate, and/or develop new products.

b) Financial Data

• Prevent and investigate fraud and other illegal activities;
• Enable payments on the Platform, as applicable.

c) Browsing and Device Data

• Ensure the proper functioning of our Platform and Services in support of our analytical efforts;
• Operate and improve our Platform and web features, as well as simplify User interaction;
• Ensure Platform security;
• Comply with legal obligations regarding data collection and sharing with public authorities, as required by applicable laws and regulations;
• Help us understand your usage patterns of our Platform and implement improvements;
• Recommend Platform services or features to the User, including third-party services that may be of interest;
• Prevent attacks and monitor consecutive user logins to provide a better experience; and
• Prevent and investigate fraud and other illegal activities.

d) Communication and Support Data

• Provide User support;
• Respond to service requests.

In addition to the purposes listed above, we may use your Personal Data for any other purpose disclosed to you before you provide us with your Personal Data or that is reasonably necessary to provide the Services or other related products and/or services, with your permission or under your direction.

Attention: When contacting us by email or through forms on our Platform, or when publicly sharing content through our Services, we ask that you do not send us any sensitive information about yourself or third parties.

We do not intentionally collect or store Sensitive Personal Data (as defined in Article 5, II of the LGPD). However, if you voluntarily provide us with information regarding racial or ethnic origin, religious beliefs, political opinions, union membership, or membership in religious, philosophical, or political organizations, health or sexual life data, genetic or biometric data, we may process such sensitive information.

4. Classification of Personal Data

All Personal Data processed in the context of using the Platform is classified by Basemaker as “Confidential.”

5. Sharing of Personal Data

Basemaker does not sell or trade your Personal Data. As a technology platform that connects Advertisers and Creators, some profile data from Creators may be made publicly available to Advertisers so they can connect with Creators to carry out campaigns.

5.1. Service Providers. Basemaker may share your Personal Data with third-party service providers involved in technology, financial, accounting, legal, and nonprofit advisory activities, as indicated below:

a) Software and IT systems provider
Website hosting services (including cloud storage), application or software optimization services, customer relationship management software, email service providers, or system maintenance services.

b) Payment service provider
Third-party payment processing services.

c) Marketing and advertising agencies
Assistance in reaching potential new customers through multiple communication channels, or sharing with affiliated companies that promote our services on their websites.

d) Customer service provider
Assistance with consumer support services.

e) Fraud prevention and information security provider
Identity verification, fraud prevention, or credit risk reduction services to protect our website (Platform) and our business.

In addition to the items listed above, your Personal Data may be shared with service providers for the following purposes:

• User authentication and identification;
• Verification of authenticity of information and documents;
• Risk prevention, fraud prevention, and ensuring security;
• Enrichment of User information for profile analysis;
• Delivery of advertising campaigns and service offers;
• Improvement of our Services, the Platform, and the operation of new products or services;
• Prevention and resolution of technical or security issues;
• Support, maintenance, and User service; and
• Analytical studies.

5.2. Judicial, Administrative, or Government Authorities. In the event of a legal or regulatory order, Basemaker may share your Personal Data with competent judicial, administrative, or governmental authorities, as provided by law.

5.3. Consent. We may disclose your Personal Data for any purpose with your consent.

5.4. Corporate Transactions. We may disclose your Personal Data to a potential buyer or investor in the event of a merger, acquisition, restructuring, reorganization, dissolution, sale, or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar process.

5.5. Audit. In addition to the cases mentioned above, Basemaker may share your Personal Data for legal audit (due diligence) purposes and with auditing firms solely to conduct audits of Basemaker’s operations and to comply with legal or regulatory obligations.

Please note that we may disclose anonymized information about our Platform Users without restriction, since such information does not identify any specific individual.

6. Personal Data of Followers or Users of Creators’ Profiles

The Platform is a technology solution for Creators and Advertisers and may therefore access Creators’ Profile data, including data about their followers and users. However, in this activity, the Platform acts solely as a data processor of Creators’ followers/users, in accordance with the LGPD. The relationship between followers and users of the Creators’ Profiles takes place directly between the Creators, the respective platform or social network, and their users.

7. Cookies and Other Tracking Technologies

As indicated in Clause 2.3 above, Basemaker records activities performed by Users, creating, when possible and applicable, logs (records of activities carried out on the Platform and during the use of Services) that include: the IP address of the User’s device, access and actions performed by the User, the date and time of each action, and information about the device used by the User, such as operating system version, browser, and geolocation.

In addition, Basemaker uses certain technologies to monitor activities performed on the Platform, such as cookies. A cookie is a text file placed on your hard drive by a web server, without the ability to run programs or infect your computer with viruses. On our Platform, cookies are used to personalize your online experience, save you time, and optimize your browsing. You can block some of these cookies on your computer. The Personal Data collected about our Users is used in accordance with this Policy.

In general, we use cookies to:

• Identify preferences of each User and, accordingly, deliver ads of interest;
• Conduct research and diagnostics to improve the experience and content of our Platform;
• Prevent fraudulent activities; and
• Improve the security of our Platform.

8. Security Controls and Risk Mitigation

Basemaker uses various technical and organizational security measures to protect your Personal Data. Our efforts aim to mitigate the risks of destruction, accidental or unlawful loss, alteration, disclosure, unauthorized access, or any other form of unlawful or improper processing. For this purpose, Basemaker applies strict access controls based on the principle of least privilege to its information technology systems to protect Personal Data against potential security incidents.

Basemaker makes significant efforts to ensure the security of your Personal Data and takes precautions to prevent any misuse of Personal Data. However, the Internet cannot be considered a completely secure environment, and therefore we cannot guarantee complete security of our Users’ data. Unauthorized access or use, hardware or software failures, and other factors may compromise the security of our Users’ information at any time.

In line with the above, given the current state of technology, it is not possible to guarantee that any data transmission over the Internet will be completely secure. Therefore, if you identify or become aware of anything related to Basemaker that may compromise information security, we ask that you contact us as soon as possible so that incident response measures may be taken.

For the security of our Platform, if we have reason to believe that the information provided to us is not true or that there are signs of fraudulent activity, we may suspend or terminate your account and refuse to provide you with any of our Services. Any error, delay, loss, or damage caused by incorrect or outdated Personal Data is the sole responsibility of the User. Furthermore, if Basemaker identifies inconsistencies or potential risks involving one of its Users or their activities, we may request that you provide means to validate the information provided.

Additionally, Basemaker is not responsible for security failures occurring on the User’s device, computer, mobile phone, or tablet, such as failures arising from viruses, malware, spyware, phishing, keyloggers, DNS server attacks, or DNS cache poisoning, nor for damages or problems resulting from delays, interruptions, or blockages in data transmissions occurring on the internet. You acknowledge and consent that all communication over the internet is subject to interruptions or delays that may prevent or impair the sending of orders or the receipt of updated information.

9. Information About Your Account and Access Password

To help us ensure your security and that of your Personal Data, we recommend that your Platform access password be complex, personal, and non-transferable. It is important that you protect your password and limit its use and access to your computer and mobile devices to prevent unauthorized access to your account. It is your responsibility to keep your access password in a safe and restricted location.

We therefore recommend that your access password not be obvious, such as birth dates. It is important that the password include special characters and alphanumeric elements and that it be changed periodically or in case of suspected unauthorized access.

If you believe or suspect that, for any reason, your account security has been compromised, we ask that you contact us as soon as possible.

10. Your Rights

Under the LGPD, you have the right to:

• Obtain confirmation that we process your Personal Data. In response to such a request, we will inform you whether or not we process your Personal Data. Note that if you are our customer (User), we necessarily process your Personal Data, as explained in this Policy.

• Access your Personal Data. If you are interested, you may receive a report presenting the Personal Data held by us that belongs to you.

• Correct Personal Data that is incomplete, inaccurate, or outdated. If you believe your Personal Data is incorrect, you may request correction, indicating what needs to be changed and why. We may request some proof to carry out the change.

• Request anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed Personal Data, in accordance with the LGPD. If you believe that we are processing your Personal Data unnecessarily, excessively, or unlawfully, you may request that the Personal Data be anonymized, blocked, or deleted.

• Request portability of your Personal Data to another service or product provider, subject to our trade and industrial secrets, once regulated by the National Data Protection Authority (ANPD). You own your Personal Data. Therefore, you may request that this Personal Data be transferred to another service or product provider, in accordance with ANPD regulations, provided that trade and industrial secrets are respected.

• Request deletion of Personal Data processed on the basis of your consent, except in cases of data retention permitted by law. If your Personal Data is processed based on consent, you may request its deletion. However, the LGPD allows data retention for purposes such as compliance with legal or regulatory obligations; research by a research entity, with anonymization whenever possible; transfer to a third party; or exclusive use by the controller, provided it is anonymized.

• Obtain information about with whom we share your Personal Data. You may request that we inform you which entities we share your Personal Data with.

• Obtain information about the possibility of not providing consent and the respective consequences. When consent is used as the legal basis for processing Personal Data, you have the right to be informed about the option not to provide consent and the consequences of refusal.

• Revoke your consent for the processing of your Personal Data. If your Personal Data is processed based on consent, you may revoke such consent. In this case, any processing based solely on consent will be discontinued.

• Object to processing that violates the LGPD. If you believe that we are processing your Personal Data in a manner contrary to the LGPD, you may object to such processing. The request will be carefully analyzed, and if we agree, the processing of your Personal Data in violation of the LGPD will be discontinued.

• Request the review of decisions made solely based on the automated processing of your Personal Data. Decisions may be made based on the automated processing of your Personal Data. If this occurs, you may request the review of such decisions.

• Petition regarding your Personal Data before the National Data Protection Authority (ANPD). If you deem it necessary, you may petition the ANPD regarding your Personal Data.

You may exercise any of the rights above by sending an email to privacidade@basemaker.co.

Before responding to a request to exercise the rights mentioned above, we may ask you to provide some information to confirm your identity.

11. Do You Need to Provide Your Consent for Basemaker to Use Your Personal Data as Described in This Policy?

The LGPD establishes various situations in which the processing of Personal Data is permitted regardless of the data subject’s consent. These are known as “legal bases for data processing.”

This means that if you choose to use our Platform, in some cases we may collect and process your Personal Data independently of your consent (if there is a legal basis under the LGPD that allows us to do so), such as for the performance of preliminary procedures or for the execution of a contract with you, for compliance with legal and regulatory obligations, for the regular exercise of rights in contracts or in judicial, administrative, or arbitration proceedings, for credit protection, for fraud prevention and user security, in the processes of registration identification and authentication in electronic systems, for the legitimate interests of Basemaker or third parties, among others.

In other cases, we will request your consent to use your Personal Data. It is important to note that revoking your consent will only oblige us to cease processing Personal Data carried out exclusively on the basis of consent.

12. Storage and Deletion of Personal Data

We have structured our Platform and operations so that your Personal Data is not retained in an identifiable manner longer than necessary. This means that we only retain Personal Data for as long as needed to fulfill the purposes described in this Policy.

However, we may retain your Personal Data, among other reasons, for compliance with legal and/or regulatory obligations, for the exercise of rights in judicial proceedings and administrative and/or arbitration procedures, for fraud prevention, and for the regular exercise of our rights. We may also retain Personal Data in anonymized form—that is, without such data being or becoming linked to you—for longer periods, as permitted by law.

Information we collect regarding Users’ IP addresses and access records of registered Users is stored for at least six (6) months, as required by Article 15 of Law No. 12.965/2014 (Marco Civil da Internet).

13. Third-Party Websites

As a resource for our Users, our Platform may contain links to other websites on the Internet. This Policy does not apply to such third-party websites. Basemaker is not responsible for these websites or their content, nor does it share, endorse, monitor, validate, or accept how such websites or content storage tools collect, process, and transfer your personal and private information. The information practices or content of such websites are governed by their own privacy statements. We recommend that you review the respective privacy policies of such websites to properly inform yourself regarding the use of your personal information.

14. Use by Children and Adolescents

Any processing of Personal Data belonging to children and adolescents will be carried out in accordance with the law and subject to all specific requirements, including obtaining consent from one parent or legal guardian, where applicable.

15. International Transfer of Personal Data

Although Basemaker is headquartered in Brazil, your Personal Data may be transferred to other countries, for example, to the servers of cloud storage service providers abroad. In cases where your Personal Data is transferred outside Brazil, we will adopt all appropriate measures and those required by law to ensure that your Personal Data remains properly protected and that such transfer is carried out in accordance with one of the mechanisms provided for in the LGPD and any other applicable regulations.

16. Changes to This Policy

Basemaker may modify, update, extend, or otherwise change the content and scope of this Policy at any time and at its sole discretion. In such cases, we will publish these changes on our Platform with the indication of the last update date (which you can find at the top of this Policy).

Every time we substantially change this Policy, such changes will be valid, effective, and binding once they are: (i) published on the Platform; and/or (ii) sent by email to Users registered on our Platform.

Continued use of our Platform and Services after publication on the Platform and/or email notification about changes to our Policy will be considered your consent to such changes in order to continue following our privacy practices. In cases where changes to this Policy require your consent, Users will be asked to acknowledge the new terms of this Policy after the change in order to continue using the Platform and receiving the Services.

Users should check the updated version of this Policy every time they visit the Platform.

Basemaker encourages you to periodically revisit this Policy to stay informed about our privacy practices.

17. Support and Contact Channel

If you wish to make a complaint or clarify any questions, please contact our Data Protection Officer at the following email address: privacidade@basemaker.co.

You may also send a message to the National Data Protection Authority. However, we kindly ask that you first attempt to resolve any issues directly with us, as our main concern is to keep our Users satisfied with our Platform and Services, and we will make every effort to fulfill this mission through clear and attentive communication with our Users.

18. Governing Law

This Policy shall be interpreted in accordance with the laws of the Federative Republic of Brazil. The courts of the Judicial District of São Paulo, State of São Paulo, are hereby chosen to settle any disputes arising from this Policy, with the express waiver of any other jurisdiction, however privileged it may be.