Privacy Policy

What is personal data?

Personal data is any information capable of directly or indirectly identifying an individual (through association, for example), such
as name, CPF (Brazilian tax identification number), email, among others.

Who controls your personal data?

For the purposes of applicable legislation, a data controller is the person responsible for decisions regarding the processing of
personal data. BOCOM BBM is the controller of your personal data, which is held by us, and uses it to achieve the purposes described
in our policies.

COLLECTION OF YOUR PERSONAL DATA:
COLLECTION OF YOUR PERSONAL DATA
Direct collectionPersonal data is collected directly from the data subject through forms, contracts, registration forms, business interactions, and other official bank channels. Examples include: name, CPF, email address, phone number, and banking information, among others, provided by the user or customer in the context of the business and contractual relationship.
Indirect collectionThe bank may obtain personal data indirectly, such as by recording telephone calls, exchanging corporate emails, or accessing registration information from organizations to which the data owner belongs. This data is not processed routinely, but may be used for specific purposes, such as investigations or compliance analyses.
Data Obtained from Other SourcesBOCOM BBM also processes personal data obtained from public sources (press, public websites, public databases) or legitimately shared by third parties, such as service providers and companies within the same economic group.

Learn more about personal data and about your rights.

What personal data is collected by BOCOM BBM?
BOCOM BBM collects essential personal data for identification, registration, and contact of all audiences (candidates, third parties, clients, and employees). Among the main data collected are: full name, date and place of birth, gender, email address, residential address, telephone number(s), and identification document data such as RG (Brazilian national identity card), CPF (Brazilian taxpayer identification number), and CNH (Brazilian driver’s license), as well as a photo. This data is processed according to the purposes outlined in specific policies, respecting current legislation and privacy principles.

What is the purpose and treatment of the personal data collected?
The personal data collected by BOCOM BBM is processed to facilitate institutional relationships, comply with legal and regulatory obligations, ensure the security of operations, carry out selection, hiring, service provision, customer service and support processes, and enable communication between the parties. Data processing involves operations such as collection, storage, classification, use, access, transmission, processing, archiving, deletion, modification and transfer, always in accordance with current legislation and the principles of privacy and data protection. These purposes and methods of processing are common to the privacy policies of candidates, third parties, clients, and employees, ensuring that data is used only for legitimate purposes necessary for the relationship with BOCOM
BBM

With whom do we share personal data?
BOCOM BBM may share personal data with entities essential to the functioning of its institutional activities, including other companies within the economic group, contracted service providers (such as technology, human resources, and healthcare suppliers), third parties involved in information verification, as well as public administration bodies and competent authorities, whenever necessary to comply with legal or regulatory obligations or to ensure the security and integrity of processes. This sharing is carried out in accordance with the purposes outlined in the privacy policies and respecting the limits established by current legislation.

How does the transfer of personal data outside of Brazil work?
Under certain circumstances, we may transfer your data to another country. You acknowledge that data protection laws in other countries may not guarantee the same level of data protection as the data protection laws applicable in Brazil. For transfers to third countries where there is no governmental recognition that they possess an adequate level of data protection compared to the LGPD (Brazilian General Data Protection Law), we will implement contractual and operational data transfer mechanisms that meet the standard imposed by the LGPD. The international transfer of personal data to companies within our economic group located in foreign countries is governed by an intra-group agreement on international data transfer.

How long will we store your personal data?
The personal data collected by BOCOM BBM is stored and maintained for the time necessary to comply with legal and regulatory obligations, preserve the legitimate interests of the bank, or safeguard the regular exercise of rights in judicial, administrative, or arbitration proceedings. Data processing ends when the purpose for which it was collected is achieved, when the data owner requests its deletion, or when there is a legal requirement. After termination, the data is deleted, except in cases provided for by law or the privacy policy.

What are my rights as a personal data owner?
You have several rights regarding your personal data processed by BOCOM BBM. These include:

  • To receive clear and complete information about the processing of your personal data, including details about its
    sharing with third parties;
  • Request access to your personal data and/or confirmation of the existence of personal data processing by BOCOM
    BBM;
  • Request that we correct any inaccurate, incomplete, or outdated personal data;
  • To object to data processing activities, to request anonymization and deletion of personal data, in specific
    circumstances;
  • Request the portability of your personal data;
  • You may revoke your consent at any time when BOCOM BBM processes your personal data based on your consent.
  • File a petition regarding your data against the controller with the national authority.

 

The exercise of these rights may be subject to legal limitations or the protection of BOCOM BBM’s trade secrets. To exercise your rights, simply contact the Data Protection Officer or their substitute, as indicated in the policy.

What are cookies and how do we use them?
Cookies are small text files saved on your computer, tablet, or phone when you visit the BOCOM BBM website. They collect and store browsing information, allowing applications to function correctly, authenticate users, and analyze service performance. BOCOM BBM uses essential cookies, necessary for the website to function, and analytical cookies, which help improve the user experience anonymously. You can configure or disable cookies in your browser preferences, remembering that disabling essential cookies may impact the use of the website. For more details, please consult the privacy policy.

Below are the main terms defined in BOCOM BBM’s privacy policies, presented in a comprehensive and coherent manner:

TermDefinition
Personal DataInformation that identifies or can identify an individual, such as name, CPF
(Brazilian tax identification number), address, email, phone number, among
others.
Data OwnerNatural person to whom the personal data being processed refers.
ControllerA natural or legal person, governed by public or private law, responsible for
decisions regarding the processing of personal data. In the context of BOCOM
BBM, the bank itself is the controller.
OperatorA natural or legal person who processes personal data on behalf of the
controller.
TreatmentAny operation performed with personal data, such as collection, production,
reception, classification, use, access, reproduction, transmission, distribution,
processing, archiving, storage, elimination, evaluation or control of information,
modification, communication, transfer, dissemination or extraction.
ConsentA free, informed, and unequivocal expression of consent by which the data
owner agrees to the processing of their personal data for a specific purpose.
PurposeThis is why personal data is collected and processed, always in a specific and
legitimate manner.
SharingTransfer of personal data to third parties, partners or service providers,
respecting the legal bases and purposes foreseen.
AnonymizationThe process by which personal data loses the possibility of being associated,
directly or indirectly, with an individual.
DPOPerson designated by the controller to act as a communication channel
between the controller, data owne, and the National Data Protection
Authority (ANPD).
CookiesSmall text files stored on the user's device when accessing the website, used
to ensure the proper functioning of applications, authentication, performance
analysis, and improvement of the user experience.

These definitions are essential for understanding the basic concepts used in the bank’s privacy policies. To consult
the complete list of terms and details, access the BOCOM BBM privacy policy.

LEARN MORE

For more information about the processing of your personal data, please contact the Data Protection Officer (“DPO”) of BOCOM BBM:

Monique Verboonen de Carvalho – DPO
Vitor Tostes – Deputy DPO

Contact: protecaodedados@bocombbm.com.br

BOCOM BBM processes personal data in accordance with the General Data Protection Law (Federal Law No. 13.709/18 – LGPD) and other applicable laws regarding privacy and data protection. The bank also observes specific legal and regulatory obligations, such as fraud prevention, internal controls, financial and tax regulations, health and safety, among others, always respecting the limits established by current legislation.

BOCOM BBM’s privacy policies may be updated periodically to reflect legal, regulatory, or operational changes. Users are advised to regularly consult the current policy to stay informed of any changes. In the event of significant changes, the bank may notify data owthrough available official channels.

For more information on applicable legislation and any changes, please see the BOCOM BBM privacy policy