Privacy Policy

Starting date of the term of this Policy: 9/23/2022

The purpose of this agreement is to explain the rules and conditions that will govern the relationship between APOLOPAG, and users for the use of payment services and tools that allow the acquisition, by the user (“USER”), of products and/or services from a certain Website (as defined below) and to do various transactions and/or financial services (“APOLOPAG SERVICES”). In addition, APOLOPAG establishes the privacy policy that will rule its performance in dealing with User’s information.


APOLOPAG reserves the right to change the terms of use and privacy policy at any time.


1.1. For the purposes of this Policy, it is considered:

(i) “Affiliates”: any company directly or indirectly controlled by APOLOPAG, or companies that control, directly or indirectly, APOLOPAG, or companies that are under common control of APOLOPAG.

(ii) “Functionality”: APOLOPAG’ application, link and/or program, already implemented and/or to be implemented in the future, through which are provided a part, or all, of the APOLOPAG Services.

(iii) “Internet Protocol Address (IP Address)”: the code assigned to a Terminal on a network to allow identification of the User, defined according to international parameters.

(iv) “Internet”: the system consisting of a set of logical protocols, structured on a worldwide scale for public and unrestricted use, with the purpose of enabling data communication between terminals through different networks.

(v) “APOLOPAG Services”: means the services defined in the preamble of this Policy.

(vi) “Website”: is the provider of products and/or services that uses the Functionality for providing the APOLOPAG Services.

(vii) “Terminals”: ​​computers, notebooks, netbooks, smartphones, tablets, palm tops and any other devices that connect to the Internet.

(viii) “User“: any individual who use the APOLOPAG Services, over 18 (eighteen) years or emancipated, fully capable of performing the acts of civil life, or those absolutely or relatively incapable, duly represented or assisted.

1.2. The clause titles are for reference only and do not affect the interpretation of this Policy.

1.3. Unless otherwise provided for in this Policy, words in the singular include the plural and vice versa; words in the masculine gender include the feminine, the neuter gender and vice versa.

1.4. By using the APOLOPAG Services, the User agrees that APOLOPAG may modify this Policy unilaterally and at any time regardless of prior notice.

1.5. Also the fees may changed without prior notice, opportunity in witch the User declares to know that eventual modification of these fees will be requested by the Website that User acquire products and/or services or by legal determination.


2.1. The User fully consents, agrees and accepts the provisions of this Policy when using the APOLOPAG Services. The APOLOPAG Services are provided in accordance with this Policy, therefore, the User must only use the APOLOPAG Services if he fully agrees with this Policy.

2.2. This Policy does not apply to services offered by other companies or individuals, including the services of Websites that use APOLOPAG as a means of payment. APOLOPAG only guarantees the security and integrity of the data that the User provides directly to APOLOPAG through the information that the User provides on the Website’s “checkout” page or on the APOLOPAG Services page.


3.1. APOLOPAG needs some information from the User to identify the User and enable payment for the purchase of products and services from the Website, and, eventually, provide other services and enable financial transactions. This User Information is acquired to protect the User and improve the provision of the APOLOPAG Services.

3.1.1. APOLOPAG ‘ Services are available on the Websites via boleto bancário, deposit, bank transfers, credit cards, PIX and digital wallets. In all cases APOLOPAG will be the beneficiary of payments. In the event that APOLOPAG outsources the recipient of payments, APOLOPAG hereby undertakes to inform, previously, the User about it.

3.2. In the event of using the deposit and/or bank transfer services in the purchase of an item. The User will be directed to a APOLOPAG page, where it will be necessary to provide information on the order number, type of service (if via deposit or via bank transfer), number agency, account number, name of the account holder, CPF number of the account holder, voucher number, date and time of the voucher, in addition to sending the proof of payment as a document to validate the purchase.

3.2.1. APOLOPAG hereby informs that the time period of processing payments via deposit and/or transfer is 30 (thirty) minutes after submission of all necessary information pursuant to Clause 3.2 above.

3.2.2. Eventually in addition to necessary informations in Clause 3.2, other informations may be requested to the User. The payment processing only occured after providing complementary informations.

3.2.3. If there are any inconcistencies in data (personal, transfers, deposits, payments and others), the time of processing will be considered that one sufficient to resolve the inconcistencies.

3.2.4. In case of deposits, bank transfers or boleto bancário payment that occur after banking hours, the processing may occur only in the next business day subsequent the deposit, transfer or payment.

3.2.5. The User declares since now have knowledge of all the proccedures made, by any metod available in APOLOPAG platform only occur after payment proof made by the User.

3.3. The User will be forwarded to a APOLOPAG page in the event of using bank slip services, where it will be necessary to fill in information such as name, e-mail, CPF number and personal telephone number.

3.3.1. Eventually other informations may be requested from the Users.

3.3.2. APOLOPAG informs that the average processing time is 30 (thirty) minutes after the payment is made, and in the case of using any digital bank, the average processing time is one business day, respected the conditions provided in 3.2.2, 3.2.3, 3.2.4 and 3.2.5 clauses.

3.4. The User declares since now have knowledge that payments clearing period may be changed regardless of prior notice when:

i) APOLOPAG system is offline for any reason.

ii) Bank system is offline for any reason

iii) User make payment in weekends, national or municipal holidays.

3.5. As mentioned above, in order for the User to use the APOLOPAG Services, it will be necessary to register on the Website’s “checkout” page, or, as the case may be, create an account on the APOLOPAG Services page, providing some personal data of registration, including, but not limited to full name, telephone, address, e-mail, CPF and etc. In addition, the User will enter on the Website their financial information, inter alia, current account data and credit card number. Other registration data for identification of the User and/or access to the Website and/or the Services of APOLOPAG, as the case may be, it might be requested, if necessary for the identification of the User. Personal data, financial information and other registration data are called (“User Information”).

3.5.1. The User undertakes to provide, at the time of registration in the Functionality, true information, being civilly and criminally responsible for the authenticity of the information and for the damages that such violation may cause. The User also undertakes to update the data and information provided at the time of registration in case of any change or alteration, as soon as such change occurs.

3.5.2. The User declares have knowledge that service use may be suspended while your data are not updated, and exempt APOLOPAG for any responsibility for inability for use the services while your data are not updated.                        

3.6. APOLOPAG will be responsible for the custody of User Information, when such maintenance is imposed due to the provision of APOLOPAG Services, legal and/or regulatory obligations, especially the General Data Protection Laws and the rules of the Central Bank, as applicable. Or, even when maintenance is necessary to comply with a court order or within the scope of legal and/or administrative proceedings and questioning of third parties arising from the activities performed by the User on the Website and/or on the pages of the APOLOPAG Services.

3.7. APOLOPAG may offer the User access to the APOLOPAG Services through any of the Terminals, always depending on the accessibility of the partner Websites. The clauses of this Policy apply to all accesses and uses by mobile devices and to accesses through Terminals on the Website.

3.8. For the purpose of complying with certain legal obligations, APOLOPAG reserves the right to impose limits on the amount of monthly, weekly or daily transactions to be carried out by a specific User, monitor the transactions carried out by the User and/or open the necessary information to regulatory bodies for the purpose of protecting the APOLOPAG itself and its partners.

3.8.1. The imposition of limits on the amount of monthly, weekly or daily transactions independ of prior notice and may occur at any time.

3.8.2. The imposition of limits may occur to quantity or amount of the transactions

3.9. When the User uses a APOLOPAG Service, the APOLOPAG may receive information about the User’s location, his device and his Internet Protocol Address (IP Address), including a unique identifier of his device. APOLOPAG may use this information to provide location-based services, such as advertisements, search results and other personalized content, within the limits of current legislation.

3.9.1. Under no circumstances will the User have access to the source code of the Features, considering that APOLOPAG owns this.

3.10. The User hereby declares to be aware that small programming defects (bugs) are common to all computer programs, exempting APOLOPAG from any liability for damages arising from such bugs, eventually existing or arising from the use of the APOLOPAG Services.

3.10.1. Furthermore, APOLOPAG ‘ liability will be limited to the amount of the transaction that caused the loss to the User, not being liable for indirect, special, fines or damages resulting from force majeure and/or acts of God.

3.11. In case of using the APOLOPAG Services on behalf of a legal entity, by signing these Terms of Use and Privacy Policy, the User is responsible for the legal representation of the legal entity in question, being responsible for its acts.

3.12. The User declares to be aware and acknowledges that APOLOPAG:

(i) It does not act or replace consultants and advisors specialized in contracting financial services, even if such services are indicated on the Website;

(ii) It is not responsible for the financial decisions that the User may make through the Features; and

(iii) It is not responsible for the fees, quotations, terms and other terms related to the services and products indicated on the third party’s Website. For the sake of clarity, APOLOPAG is only and solely responsible for the fees, quotations and terms when indicated in the Functionalities for the performance of APOLOPAG Services.

3.13. The Use declares has knowledge the cash-out may be credited in 3 (three) business days after APOLOPAG receive the request.

  1. i) The User has knowledge the cash-out only will be made in 3 (three) business days if all personal and banking data are correct and the beneficiary of the transaction is the User.

3.14. The User may request support in the event of failures and/or defects in the APOLOPAG Services, which will always be performed remotely by accessing the electronic address https: in the item “suporte ao cliente”.


4.1. The User is aware of and agrees the deadline to make the values devolution, if approved by the Website, will occur by APOLOPAG in maximum 10 (ten) business days.

4.2. The 10 (ten) days deadline mentioned in Clause 4.1 will be counted after the User send all the data necessary to effective the values devolution.

4.2.1. The necessary data consist in:

  • Complete Name of the owner of the account;
  • TAX ID;
  • Bank;
  • Agency and account (the same that make the transfer or the same that pay your bank slip);
  • Payment proof;

4.3. If any data described in Clause 4.2.1 is not informed, the deadline to make the devolution may be changed, opportunity in wich the deadline of 10 (ten) business days will be counted after the User send the missing data.

4.4. The 10 (ten) business days may be changed if the Website do not send the amount to APOLOPAG, opportunity that the User will be informed of the new devolution deadline.

4.5. For credit cards, the chargeback will also depend on the chargeback policy of the card operator, and may occur after 10 (ten) business days period.


5.1. The User is aware of and agrees to the collection, storage and treatment of User Information sent and/or transmitted by the User under the terms set out in this Policy. APOLOPAG declares and guarantees that the collection, storage and treatment of User Information are always carried out in accordance with current legislation.

5.2. APOLOPAG does not consider as User Information: (i) information that has been generated anonymously, in a way that does not identify a specific User; and (ii) the information obtained by APOLOPAG autonomously, on the Internet or by other independent means.

5.3. APOLOPAG´ operations are supported by a network of computers, cloud servers and other infrastructure and information technologies, including, but not limited to, infrastructure from third-party service providers. APOLOPAG and its third party service providers will store and process User Information with confidentiality and care, always in accordance with current legislation.

5.3.1. The User agrees that APOLOPAG may transfer User Information it collects through the APOLOPAG Services to other countries where our third party service providers are located. In this case, APOLOPAG will use its best efforts to protect User Information as described in this Policy, respecting the applicable laws, including those of the respective countries.

5.4. User Information is collected, stored, treated, processed and used by APOLOPAG for the following purposes:

(i) provide the APOLOPAG Services and Website support;

(ii) process transactions, including financial transactions, and send notices about your transactions;

(iii) verify your identity;

(iv) resolve disputes, charge fees and resolve issues;

(v) manage risk or detect, prevent and/or remedy fraud or other potentially prohibited or illegal activities;

(vi) detect, prevent or remedy violations of applicable policies or contracts;

(vii) improve the APOLOPAG Services;

(viii) improve the User’s browsing experiences on the Website and on the pages of APOLOPAG Services, when applicable;

(ix) allow the provision of services more personalized and adequate to the User’s needs; and

(x) allow communication between the User and APOLOPAG, including by sending and receiving e-mails.

5.4.1. The User is aware and authorizes that their browsing records in the

Features, when implemented, are provided by APOLOPAG to its Affiliates and their respective partners or contractors to provide any service related to the Website and/or Features, without individual indication of the User and/or allowing their identification and for the purposes provided for in the Clause 5.4.

5.5. APOLOPAG preserves the privacy of Users and shares their User Information with third parties in accordance with the terms and conditions set out in this Policy, or by force of law or court order. APOLOPAG may combine User Information with information it collects from other companies and use it to improve and personalize the APOLOPAG Services, content and advertising of APOLOPAG. This practice is already authorized by the User

5.5.1. APOLOPAG may use User Information to identify you, and, eventually, create a profile that allows the provision of Services by APOLOPAG and/or its Affiliates more efficiently. In addition, APOLOPAG may use User Information to disclose other services of APOLOPAG and its Affiliates, in addition to publicizing events and manuals of the latter of these Affiliates.

5.6. As provided for in Clause 5.5. above, APOLOPAG may share User Information, whenever permitted by applicable law, as follows:

(i) Affiliated companies of APOLOPAG to provide products and services (such as registration, transactions and support, compliance services and customer communication), in addition to helping to detect and prevent potentially illegal acts, violations of this Policy and fraud in User transactions with the Website;

(ii) Affiliated companies of APOLOPAG to enable marketing efforts for products or Services of APOLOPAG, its Affiliates, and, where appropriate, third parties;

(iii) financial institutions, Affiliated or not, with which APOLOPAG has collaborated to create or offer products in addition to the financial institutions that APOLOPAG uses to perform the APOLOPAG Services. These financial institutions may only use this information to market products related to APOLOPAG, unless the User allows other types of use; (iv) credit companies and collection agencies to report User Information as permitted by law;

(iv) credit companies and collections agencies to report User’s informations, as allowed by the law;

(v) partners, including bankers, as required by credit card association rules for inclusion on the list of eliminated sellers (if you meet the criteria for a violation of this Policy);

(vi) companies with which APOLOPAG intends to associate (through any form of association, including, but not limited to, mergers and acquisitions of third parties). In any case, APOLOPAG will use its best efforts to ensure that the newly incorporated entity follows this Policy with respect to User Information;

(vii) law enforcement authorities, government officials or other third parties to comply with a subpoena, court decision or other legal procedure or requirement applicable to APOLOPAG or an Affiliate, especially to comply with the law or credit card association rules, or, further, when, at APOLOPAG ‘ discretion, disclosure of User Information that proves necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of this Policy;

(viii) fraud prevention and risk management company, which may be an Affiliate of APOLOPAG, when necessary to help prevent fraud or assess and manage risks in completing transactions between User and the Website. In relation to efforts to prevent fraud, APOLOPAG may also share User Information with the Website (APOLOPAG customers) in case of suspension or restriction of the User’s account and login, disputes regarding transacted amounts, complaints, chargebacks or other scenarios referring to the sale or purchase of products, and also for them to operate buyer evaluation programs;

(ix) a customer service company, for the purpose of servicing the User, including supporting Your accounts or resolving disputes (eg, billing or transactions);

(x) freight company for services related to purchases made through APOLOPAG;

(xi) legal compliance specialist that assists APOLOPAG to meet the verification requirements against money laundering and terrorist financing; and

(xii) service providers that assist APOLOPAG in commercial and financial operations, such as fraud prevention, billing, marketing, customer service, cloud storage services and technology services. The contracts signed with these service providers determine that the User Information is only used in the services they perform for APOLOPAG and not for their own benefit.

5.6.1. The User have knowledge and agrees that in case of legal imposition or court order, the informations may be transmited regardless of authorization of the User

5.7. APOLOPAG will protect User Information with physical, technical and administrative security measures to reduce the risk of loss, misuse and unauthorized access, disclosure and alteration. When transferring User Information to third parties and/or affiliated companies, APOLOPAG will sign instruments by which it will seek to ensure that these third parties and/or affiliated companies comply with the terms of this Policy. APOLOPAG uses security measures, such as firewalls and data encryption, in addition to making its contracted third parties apply physical access controls to data centers, in addition to information access authorization controls.

5.8. APOLOPAG takes steps to verify User Information to prevent fraud in its customers’ transactions. APOLOPAG may provide User Information to third parties to complete a transaction, such as name, account name, billing address, or other information necessary to promote the reliability and security of the transaction. If the transaction is suspended, if fails or even later invalidated, APOLOPAG can also provide details of the unsuccessful transaction.

5.9. In case of extrajudicial notification or petition requesting the disclosure of the user’s registration or browsing data, including IP address, due to alleged use of the internet for illegal or illegitimate purposes, the User will be notified of the request for authorize or not the disclosure of the requested data. The deadline to the User authorized the disclousure of the data will be in the notification send by APOLOPAG and must be must be compulsorily fulfilled.

5.9.1. With the User’s timely authorization, APOLOPAG will respond to the notification revealing the requested data. If the User does not respond to APOLOPAG ‘ request within the deadline or do not authorize the disclosure of your data, we will inform the applicant that the information can only be provided by court order. The User will be obliged to bear any costs, expenses, conviction and legal fees for loss of suit and contract imposed on APOLOPAG due to any legal demand for the disclosure of said data, from now on in this case.

5.9.2. The User is aware and agrees that APOLOPAG will serve, regardless of prior communication to the User, any competent judicial authority that seeks to determine the disclosure of the User’s identity or any data provided to or collected by APOLOPAG because of its use of the APOLOPAG Services.

5.10. APOLOPAG will use its best efforts to ensure that the recipient of User Information, as mentioned above, does not use this information for purposes unrelated to the User’s acquisition of the Website’s products or services, such as direct sales, unless the User expressly agree to this.

5.11. APOLOPAG makes the User aware that each Website on which the User purchases products or services and the third parties with which the User conducts financial transactions have their own privacy policies. APOLOPAG is not responsible for any actions by the Website or its administrators, including its information protection practices.

5.12. APOLOPAG will not routinely disclose the User’s bank account and/or credit card number to the Website, except as provided in this Policy, with the User’s permission, or if necessary to comply with card association rules of credit, a court or extrajudicial subpoena, or other legal proceedings.

5.13. APOLOPAG may contact the User to send notifications about the APOLOPAG Services, to resolve issues with User Information, resolve a dispute, collect fees or amounts due, ask for their opinion through surveys or questionnaires. APOLOPAG may also contact the User by telephone, e-mail or SMS as efficiently as possible, and through text messages and pre-recorded calls or automatic dialing. Where applicable and permitted by law, the User may refuse to receive certain communications. It is APOLOPAG´ policy not to contact the User by sending unwanted or threatening messages or with charge not in relation to the request send by the User.


6.1. A cookie is a small amount of data placed on your computer’s browser or mobile device. The Privacy and Cookie Policies apply to cookies installed in browsers and to similar or analogous technologies contained in mobile device applications (herein generically referred to as “cookies”).

6.2. Cookies allow the User to be acknowledge as the same user when browsing the pages of a Website. When browsing the Website, 04 (four) types of cookies may be used:

(i) Authentication: serve to recognize a specific User, enabling access and use of the Website with restricted content and/or services and providing more personalized browsing experiences.

(ii) Security: are used to activate Website security features, in order to assist in the monitoring and/or detection of malicious or prohibited activities by these Terms of Use and/or the Privacy Policy, as well as to protect the information User’s access by unauthorized third parties.

(iii) Search, Analysis and Performance: the purpose of this type of cookie is to help understand the Website’s performance, measure the Website’s audience, check the users’ browsing habits on the Website, as well as the way in which they arrived at the Website (for example, through links from other Websites, search engines or directly by address).

(iv) Advertisement: are use to present relevant advertisements to the User, both on and off the Website or on partner Websites, as well as to find out if the Users who viewed the advertisement via Website after having seen the advertisement. Advertising Cookies can be used to remember any searches carried out by Users on the Website and/or Features and, based on searches carried out by Users, to present Users with advertisements related to their interests.

6.3. The User may disable the use of cookies and clear cache using the settings available on their device. However, by opting for this alternative, it is possible that the Website does not perform 100% of its functionality.


7.1. The User may not take the following actions to, or use of, the Website and/or the Services of APOLOPAG under penalty of civilly or criminally responsibility:

(i) any unlawful acts and/or violation of current legislation, including legal positions of Law 9613/98; and

(ii) any acts that, directly or indirectly, in whole or in part, may cause damage to the Website or APOLOPAG and/or any third parties.

(iii) acts contrary to morals and good customs;

(iv) violation of third party rights, including confidentiality and privacy rights;

(v) acts that cause or provide contamination or damage any equipment of APOLOPAG, its Affiliates and/or third parties, including through viruses, trojans, malware, worm, bot, backdoor, spyware, rootkit, or by any other devices that may be created;

(vi) defraud and/or use the APOLOPAG Services for the purpose of engaging in any type of fraud that harms the Website, APOLOPAG or any third parties; (vii) perform any acts that directly or indirectly, in whole or in part, may cause damage to APOLOPAG, its Affiliates, any User and/or any third parties; and

(vii) use any business name, brand, domain name, slogan or advertising expression or any distinctive sign or intellectual property owned by APOLOPAG and/or its Affiliates.


8.1. The User is solely responsible as follows:

(i) for the accuracy and update of all User Information;

(ii) for any and all acts or omissions performed by him through his access to the Internet, the Website and/or the Functionalities, when applicable; and

(iii) to any third party, including due to non-compliance with the provisions of this Policy or any act performed from their access to the Internet, the Website and/or Functions, as the case may be.

8.2. The User will have the right to consult, free of charge, the form and all content of their personal data stored in the APOLOPAG database and to have their consent to the use of User Information for purposes other than those already provided for in this document. The deadline of these informations provided will be informed after the request.

8.3. Under no circumstances will APOLOPAG be liable:

(i) for any act or omission performed and/or damage caused by the User arising from access to the Website and/or the Features;

(ii) misuse of the Website and/or the Functionality by any User;

(iii) by links and Website (s) of partners/third parties, the User being subject to the terms of use and privacy policies of the respective Website (s);

(iv) due to failures, technical impossibilities or unavailability of the system and/or the APOLOPAG´ Functionalities due to the User’s or third parties’ fault, act of God or force majeur and

(v) by installing viruses, trojans, malware, worms, bots, backdoors, spyware, rootkits, or any other devices that may be created as a result of Internet browsing by the User, on the User’s or third parties’ equipment.

8.4. APOLOPAG may, by itself or by third parties, at any time and for any reason, at its sole discretion, without the need for any prior or subsequent notice or notification to any User, without prejudice to initiate the applicable legal measures, suspend or limit the use of the APOLOPAG Services and/or access to the Features, terminate the account of any User, at any time, in the Features and/or take other measures deemed necessary to comply with this Policy and for the proper functioning of the Website and/ or the Features. APOLOPAG may also suspend or limit the use of the APOLOPAG Services and/or access to the Features, terminate the account of any User in case of breach of the terms of this Policy and breach of legal obligation.

8.5. APOLOPAG may also suspend or limit the use of APOLOPAG services and/or its functionality, end an account of any User in case of breach of the terms of this policy and breach of legal obligation and refuses to open an account or register to your services.


9.1. It is APOLOPAG property: (i) any and all software or Functionalities used in the provision of APOLOPAG Services; (ii) the visual identity of the Features (including the graphic-visual art project of any of its pages); (iii) the business name, brand, domain name, slogan or advertising expression or any distinctive sign of its ownership inserted in the Features; and (iv) any and all content created and produced by APOLOPAG, by itself or by third parties, which cannot be used, in any way or form, by the User.


10.1. Tolerance regarding any non-compliance with any of the provisions of this Policy by any User shall not constitute a waiver of the right to demand compliance with the obligation, nor pardon, nor amendment of what is provided herein.


11.1. The term of validity of this Policy begins on the date of its publication on the Website of APOLOPAG, with a date detailed in the preamble of this Policy, except as provided in Clause 10.3 below, ending with effect on the date on which the Policy is unilaterally amended or updated by APOLOPAG. Any change and/or update to this Policy will become effective from the date of its publication on the APOLOPAG Website and/or in the Functionality and must be fully observed by the User, as the case may be regardless of prior notice.

11.2. APOLOPAG, at any time, at its sole discretion and without the need for any prior or subsequent notice to any User or third parties, may: (i) suspend, cancel or interrupt the APOLOPAG Services and access to the Features and (ii) remove, alter and/or update in whole or in part the APOLOPAG Services and/or the Functionalities, as well as their respective contents and/or this Policy.


12.1. This Policy is stablished by Swiss law. Any disputes or controversies arising from any acts performed within the scope of the use of the APOLOPAG Services and/or the Functionalities by the User, including in relation to non-compliance with the terms of this Policy or violation of the rights of APOLOPAG, other Users and/or third parties, including intellectual property rights, confidentiality and personality, will be solved in the Judicial District of Freiburg.