Privacy Policy

Policy effective date: 10.08.2022

The purpose of this agreement is to explain the terms and conditions that will govern the relationship between APOLOPAG FACILITADORA DE PAGAMENTOS INTERNACIONAIS LTDA.  (“APOLOPAG”) and the clients to the utilization of the services and payment methods tools that allow the user to purchase products and/or services on private websites (as defined below) and carrying out other transactions and/or financial services (“APOLOPAG SERVICES”) In addition, APOLOPAG establishes the privacy policy that will govern its performance in the treatment of Users’ information.

APOLOPAG reserves the right to alter and amend the terms and conditions 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) ”Feature”: APOLOPAG application, link and/or program, already implemented and/or to be implemented in the future, through which part of all APOLOPAG Services are provided.

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

(iv) “Internet”: the system constituted a set of logical protocols, structured on a global 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. For the purpose of this agreement and unless the context otherwise admits, words importing 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 APOLOPAG Services, the User agrees that APOLOPAG may unilaterally modify this Policy at any time regardless of prior notice.

1.5. The service fees may also be modified without prior notice, opportunity in which the User declares to be aware of a possible change of these fees will occur through a request on the website in which the User acquires their products and/or services or by legal determination.


2.1. The User entirely consents, agrees, and accepts the dispositions of this Policy when using APOLOPAG Services. APOLOPAG Services are provided in accordance with this Policy, therefore, the User should use APOLOPAG Services only if entirely agrees with this Policy.

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


3.1. APOLOPAG requires little information from the User to identify them and enable the payment of the acquisition of products and services on the Website, and, eventually, provide other services and enable financial transactions. This User Information is used to protect the User and improve the provision of APOLOPAG Services.

3.1.1. APOLOPAG Services are available on the Websites through boleto express, deposit, bank transfers, credit cards, PIX, and digital wallets, being though in all instances APOLOPAG will be shown as the beneficiary of the payment. In case APOLOPAG outsources the payments’ recipient, APOLOPAG commits, in advance, to inform the User about the issue beforehand.

3.2. In the event of using the deposit and/or bank transfer services, the User will be forwarded to a APOLOPAG page where it will be necessary the provision information about the order number, type of service (whether via bank deposit or via bank transfer), agency number, account number, name of the account holder, CPF of the account holder, receipt number, date and time of the receipt, in addition to sending the payment receipt document.

3.2.1. APOLOPAG informs beforehand that the average time for processing payments via deposit and/or transfer is 30 (thirty) minutes after sending all the necessary information pursuant to Clause 3.2 above.

3.2.2.Occasionally, in addition to the necessary information contained in Clause 3.2, other information may be requested from the User, and the payment processing will only occur after the additional information is provided.

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.

The User declared to be aware of the fact that every processing conducted by any available method in the APOLOPAG platform, will only occur after the confirmation of payment made by the User.

3.3. In case of utilization of the boleto express services, the User will be forwarded to a APOLOPAG page, where the provision of information such as name, email address, CPF number and phone number will be necessary.

3.3.1. Other information may be eventually required from the Users.

3.3.2. APOLOPAG informs that the average processing time is 30 (thirty) minutes after the payment, though in cases of the utilization of any digital bank, the average processing time is of one working day, complying with the conditions stated in clauses 3.2.2, 3.2.3, 3.2.4 and 3.2.5.

3.4. The User declares to be aware that the deadlines for compensation of payments might suffer modifications regardless of prior warning when:

i) APOLOPAG system is out of service for whatever reason;

ii) the bank systems are out of service for whatever reason;

iii) the payment carried out by the User occur on weekends or national or local holidays.

3.5.As mentioned above, in order for the User to utilize APOLOPAG Services, it will be necessary to register on the “checkout” page on the Website, or, as the case may be, create an account on the APOLOPAG Services page, providing some personal registration data, including, but not limited to: full name, telephone, address, email, CPF, etc. Furthermore, the User will insert on the website their financial information, inter alia, checking account data and credit card number. Other registration data for User identification and/or access to the Website and/or APOLOPAG Services, as the case may be, may be requested, if necessary, for the identification of the user, an opportunity in which the registration will only be considered finalized and the User able to use the services after the sending of the complementary information. Personal data, financial information, and other registration data are referred to as (“User Information”).

3.5.1. The user commits to provide, at the time of registration in the Feature, true information, being civilly and criminally responsible for the authenticity of the information and for the damages that such violation may cause. The User commits to update the data and information provided at the moment of registration in case of any changes or modifications, as soon as such changes occur.

3.5.2. The User declares to be aware that the utilization of the services may be suspended until the update of their registration data, as well as exempts APOLOPAG from any responsibility for the impossibility of using the services until they keep their data updated.

3.6. APOLOPAG is responsible for keeping Users’ Information when this maintenance is imposed due to the provision of APOLOPAG Services, legal and/or regulatory obligations, especially General Data Protection Law and Central Bank regulations, as applicable. Will also be responsible when maintenance is necessary to comply with a court order or in the context of judicial and/or administrative proceedings and questioning from third parties arising from the activities performed by the User on the Website and/or APOLOPAG Services’ pages.

3.7. APOLOPAG may offer the User access to APOLOPAG Services through any of the Terminals, always depending on the accessibility of the partner Websites. This Policy clause applies to all access and use by mobile devices and also to access by the Terminals on the Website.

3.8. In order to comply with legal obligations, APOLOPAG reserves the right to place limits on the amount of monthly, weekly, or daily transactions to be carried out by the User, to monitor the transactions carried out by the User and/or open the necessary information to regulatory bodies for the protection of APOLOPAG itself and its partners.

3.8.1. The imposition of limits on the number of monthly, weekly, or daily transactions does not require prior notice, and may occur at any time.

3.8.2.The imposition of limits may occur on both the number of transactions and the amount.

3.9. When the User utilizes a APOLOPAG Service, APOLOPAG may receive information regarding the User’s location, their device, and their Internet Protocol Address (IP Address), including an exclusive device identifier. APOLOPAG may use this information to provide services based on the location, such as advertising, research results, and other customized content, within the limits of current legislation.

3.9.1. Under no circumstances will the User have access to Feature’s source code, considering that it belongs to APOLOPAG.

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

APOLOPAG responsibility is limited to the transaction amount that caused financial loss to the User, not being responsible for indirect or special damage, fines, or recurring force majeure damage and/or fortuitous events.

3.11. In the case of using 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, answering for its actions.

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

(i) Does not act or replace consultants and advisors specialized in the contracting of financial services, even if such services are indicated on the website.

(ii) It is not responsible for financial decisions that the User may make through the Features; and
Is not responsible for the fees, quotes, dealines, and other terms relating to the services and products indicated on third-parties Websites’. For purposes of clarity, APOLOPAG is solely responsible for the fees, quotations, and deadlines when indicated in Features for the realization of APOLOPAG Services.

3.13. The User declares to be aware and recognizes that the withdrawals may be credited within 3 (three) business days from the receipt of the request by APOLOPAG.

The user acknowledges that the withdrawals will only be made within the period mentioned in the caput of this article if all personal and banking data are correct and the beneficiary of the transaction is the user himself.

3.14. The User may request support in case of failures and/or defects in APOLOPAG Services, which will always be carried out remotely through access to the email address.


4.1. The User is aware and agrees that the deadline for returning amounts if approved by the Website, will be carried out by APOLOPAG within a maximum period of 10 (ten) business days.

4.2.The deadline of 10 (ten) business days mentioned in Clause 4.1 shall be counted from the submission of all data necessary to carry out the refund of the amount.

4.2.1.The necessary data for the refund of values consists of:

  • Account holder’s full name;
  • holder’s CPF or CNPJ;
  • Bank;
  • Branch and Current Account (the same ones where the transfer was made or the same ones used on the boleto’s payment);
  • PIX account key: (the same one in which the transfer was made or the same one used on the boleto’s payment);
  • Payment voucher;

4.3. If any data described in Clause 4.2.1 is not informed, the period for refunding the amounts may change, in which case the period of 10 (ten) business days will be counted from the date of delivery missing data.

4.4. The period of 10 (ten) business days may be modified if the Website does not transfer the amounts to APOLOPAG, at which time the User will be informed of the new refund period.

4.5. For credit cards, the refund will depend on the cardholder’s refund policy, in which case may occur a deadline exceeding the usual 10 (ten) business days.


The purpose of this Policy is to inform, in a clear and complete way, about the USER’S Personal Data Processing, employees, and partners, to which APOLOPAG may have access as a result of the use of the Services provided by APOLOPAG within the scope of APOLOPAG System.

This Policy was elaborated in accordance with Law No. 13.709/18 (“General Data Protection Law”) and Law No. 12.965/14 (“Internet Bill of Rights”) and demonstrates APOLOPAG’S commitment to the data protection and privacy of its USERS, ensuring that the processing of personal data will only serve to enable the development of its activities and the provision of quality services, in compliance with the terms of the applicable legislation.

In cases where the USER is a legal entity, conditions set forth in this policy will apply to individuals eventually identified or identifiable as a result of the processing of data provided by the USER.

For more information and rules regarding the use of services provided by APOLOPAG, the USER must consult the applicable Agreement.

All definitions set out in Clause 5.1 of the Agreement shall apply to this policy as an auxiliary.

5.1. Compliance with this Policy

By using APOLOPAG Services and/or complying with the Agreement, the USER expressly declares that: (i) have read carefully this Policy, (ii) is aware of all its terms and conditions; and (iii) provides their express consent to the APOLOPAG’s Personal Data Processing.  In case the USER does not agree with the Processing of their Personal Data, as provided for in this Policy, they must refrain from using APOLOPAG System.

5.2. Definitions

5.2.1. Without losses to other definitions set out in this Policy and in the Agreement, the words and expressions indicated below, whenever utilized with the first capital letter, shall have the following definitions:

“Payment Account”: graphic account made available, at present moment or in the future, by APOLOPAG, through which USERS may execute their transactions.

“Agreement”: an electronic contract that regulates the rules, conditions, and limits of the services to be provided by APOLOPAG to the USER due to the use of the APOLOPAG System, including the opening of a Payment Account and flow of funds.

“Technical Use Data”: information treated by APOLOPAGdue to the use of a cellphone device, computer, or other devices that the USER may use to access the APOLOPAG System. The Technical Use Data shows how the USER utilizes the services provided by APOLOPAG, including the IP address, statistics on how pages are loaded or viewed, the websites the USER visited, and browsing information collected through cookies or similar technology.

“Anonymized Data”: information that, on its own or among other anonymized data, does not allow the identification of a person, considering the use of technical means available at the time of its processing

“Device Information”:  data that can be collected automatically from any device used to access the APOLOPAG System. That information may include but is not limited to, the device type, device network connections, device name, device IP address, device browser information, the internet connection used to access the APOLOPAG System, Geographic Location Information, and information regarding the apps downloaded on the device.

“Personal Data”: personal data is any information related to individuals that allow its identification. They may include an individual’s name, address, telephone number, and e-mail address. checking or savings account number, date of birth, affiliation, and the number of official documents (for example, Identity Card – RG, passport, CPF/ME, among others).

“Geographic Location”: information that identifies the location of the USER through, for example, latitude and longitude coordinates obtained by GPS, Wi-Fi, or cellular location triangulation. APOLOPAG System may request permission to share the current location of the USER. If the USER does not agree with the gathering of the Geographic Location information, APOLOPAG System may not work properly.

“Processing”: all operations performed with USERS’ PERSONAL DATA, such as those concerning the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, disposal, assessment, control, communication, modification, transfer, dissemination or extraction;

“USER”: legal entity or individual that provides their own Personal Data or their representatives or authorized agents to execute payment instructions, for Processing by APOLOPAG.

5.3 Collected Information

5.3.1. APOLOPAG performs the necessary Personal Data Processing  for the USER’s utilization, of the set of Services provided byAPOLOPAG, which allows the opening of a  Payment Account, loaded by one of the methods provided for in the Agreement (including credit and debit card payment) and carrying out the transfer of resources through the (“APOLOPAG System”).

5.3.2. For registration to APOLOPAG System, the USER must provide the Personal Data required by the registration form, including, but not limited to: (i) full name; (ii) firm or corporate name; (iii) CPF/ME number or CNPJ/ME number; (iv)phone number; (v) address of residence or headquarters; (vi) affiliation; (vi)e-mail address; and (vii) other information that is necessary for the user to be properly identified. The registration forms only request the necessary data for the opening of a Payment Account and to provide the services offered by APOLOPAG.

5.3.3. In order to prevent fraud, and illegal transactions and ensure the authenticity of the given information, personal data not contained in the registration form may be requested, as well as the sending of documents that allow confirmation of the data provided by the user.

5.3.4. APOLOPAG will request the filling of the USERS’ financial data necessary to provide its services, it may include: (i) credit card and/or debit card number utilized by the USER, expiration date, and security code; (ii) bank account identification data owned by the USER, containing name, banking institution number, agency number, checking account and saving account number; (iii) information about the transaction; (iv) other information regarding the transaction, such as its value, Device Information, Technical Use Data; Geographic Location; as well as USERS’ personal data, that may include full name, e-mail, phone number, mother’s name, date of birth, RG, CPF, among others. The data referring to the USER’s card will be collected at the time of APOLOPAG System using only, equipment or systems created for the capture of card transactions. The Processing of card data will be carried out only to enable the realization of the payment transaction before the accrediting companies, issuers, and flags. These data will not be stored by APOLOPAG. Will be subject to storage for an indefinite period, by APOLOPAG, related to the USERS: (i) full name, (ii) email, (iii) phone number, (iv) mother’s name, (v) date of birth, (vi) RG, (vii) CPF; and, related to the transaction, its value, in addition to (i) for card purchases, their respective last 4 digits as well as the brand identification, and (ii) for Pix, the respective key, the name of the bank, branch, account, and name of the holder. The USER financial data is collected through the platform, encrypted, and may be stored, observing the legal and regulatory applicable provisions.. This data collection may occur through APOLOPAG’s partner, payment methods service provider (situation in which APOLOPAG will not have access to such data), or by APOLOPAG itself. 

5.3.5. APOLOPAG may collect and store other USER Personal Data for (i) the compliance of requirements provided by the law or issued by the competent authorities; (ii) to prevent fraud and illicit transactions; (iii) to ensure the authenticity of the provided information; and (iv) to receive and process communications, announcements, and exercise of the USERS’ rights. Such information and personal data processing will be observed, within the legal precepts, good faith, and the strict principles of purpose, adequacy, necessity, free access, data quality, transparency, security, prevention, non-discrimination, responsibility, and accountability.

5.3.6. APOLOPAG may request other documents and information that may be necessary for the provision of the services or development of APOLOPAG’s activities. These information and additional documents may be stored by APOLOPAG for the period necessary to fulfill the purposes for which they were collected, to the extent and in strict compliance with the legal provisions and the provisions of this policy.

5.3.7. APOLOPAG may store Personal Data and other USER information when there is a legitimate interest of APOLOPAG and for compliance with legal requirements or those issued by the competent authorities. If the Payment Account is closed, APOLOPAG may store and process personal data according to this policy, adopting appropriate measures for anonymization of the personal data whenever possible and in accordance with current legislation. The USER’s anonymized data will be processed in such a way that the respective holder cannot be identified, considering the use of reasonable and available technical means at the time of its processing.

5.3.8. APOLOPAG website and internet services may collect Device Information, Technical Use Data, and Geographic Location of the USER for the purposes described in this policy. APOLOPAG websites and internet services may collect cookies (files recorded on your computer to obtain navigation information within the website), for identity confirmation and improvement of its usability and navigation. If the USER does not agree with its utilization, it may disable the use of this function using the browser’s settings.

5.4.  Sharing and using Personal Data

5.4.1. The USER’s Personal Data may be utilized by APOLOPAG for the composition registration and database formation through the Personal Data Processing, preserving the confidentiality, the USER’s individuality, and identification.

5.4.2. In order to improve its services, APOLOPAG may carry out the Device Information Processing and Technical Use Data Processing. This information will be anonymized, which means that it will not allow the identification of the USER in particular.

5.4.3. The USER’s personal data may also be shared by APOLOPAG with (i) third parties hired to provide IT, transfer of data and cloud hosting services, as long as these third parties maintain the same standard of privacy and security applied by APOLOPAG and are contractually obliged not to access the content, process or share the information, except upon express orders from APOLOPAG; (ii) APOLOPAG Group companies; (iii) APOLOPAG’s third-party service providers, including but not limited to foreign exchange service providers and others who collaborate with APOLOPAG’s provision of services; and (iv) financial institutions. These third parties may only use personal data to enable the performance of the services provided by APOLOPAG, subject to the provisions of this policy. Third parties partners are responsible for compliance and enforcement of the PCI DSS rules and requirements, which apply to all entities involved in card payment processes — including merchants, processors, acquirers, issuers, and service providers.  PCI DSS also applies to all other entities that store, process or transmit cardholder data (CHD) and/or sensitive authentication data (SAD). The Payment Card Industry Data Security Standard (PCI DSS) was developed to encourage and enhance the security of cardholder data and promote the widespread adoption of consistent data security measures worldwide. PCI DSS comprises a minimum set of requirements to protect account data and can be enhanced by additional measures and practices to further mitigate risks, as well as local, regional, and industry standards and laws. In addition, the legal or regulatory requirements may require specific protection for personal information or other data elements. PCI DSS does not substitute local, regional, or governmental laws or other legal requirements.

5.4.4. APOLOPAG may also be obliged, by law, or by order of the competent authorities to disclose the personal data of the user.

5.4.5. Transfers’ data of resources and personal data may be used by APOLOPAG for the preparation of surveys and statistics aimed at analyzing platform efficiency, the number of users, and the total amount of debits paid, among others, provided that such personal data are anonymized or in the form of total values for the creation of Statistics, so as not to identify the user. The conclusions and results of these surveys may be shared or disclosed by APOLOPAG at its discretion, as it does not contain personal data.  The conclusions and results of these surveys may be shared or disclosed by APOLOPAG at its discretion, as it does not contain personal data.

5.4.6. APOLOPAG will process the USER’s Personal Data to operate APOLOPAG System and provide the services, in the following cases:

(a) To send or request payments and/or transfers, as applicable;

(b) To authenticate user access to their Payment Account;

(c) To communicate with the USER about the use of APOLOPAG System or services;

(d) To create a connection between the Payment Account and another third-party account or platform;

(e) To check the USER’s identity;

(f) To keep Personal Data updated and the Payment Account active.

(g) To monitor and analyze the USER’s behavior, in particular, the volume of purchases and evidence of fraud, in relation to the use of the APOLOPAG System, Services, and Payment Accounts;

(h) To verify the USER’s identity to manage risks and protect APOLOPAG’s System, the services and the USER against fraud.<85/91/88% >. The risk and prevention tools against fraud will use Personal Data, Device Information, and Technical Use Data; and

(i) To comply with the obligations set forth in the Agreement, and applicable laws and regulations.

5.4.7. Subject to the provisions of the clauses above, APOLOPAG will not disclose, share, sell or use any personal data of the user, its partners, and collaborators with third parties or for commercial purposes, other than those described in this Policy.

5.5.  Advertising

5.5.1. The USER’s email informed address provided at the time of registration will be used as a means of communication by APOLOPAG, only for sending information about the APOLOPAG System, requesting documents and information related to the Registration.

5.5.2. APOLOPAG does not use third-party services to send emails on its behalf. If the USER receives an email they believe has not been sent by APOLOPAG, they must refrain from taking any action and immediately contact APOLOPAG to confirm its veracity.

5.5.3. The USER declares to be aware and agrees that to verify the completion of any transaction in their payment account, as well as to consult the loading, balance, and flow of funds in the payment account, they must always access the platform and check the information made available by APOLOPAG; not serving as proof the mere receipt of any communication by other means of communication (including email, WhatsApp, phone calls and SMS).

5.6.  Storage

5.6.1. The Personal Data collected by APOLOPAG is encrypted and stored on secure servers, using information security measures constantly updated. The information will be kept confidential and all possible measures will be taken against loss, theft, misuse, alteration, and unauthorized access.

5.6.2. The Personal Data related to the registration will be stored for as long as the USER keeps an active registration and uses APOLOPAG’s services. These Personal Data may also be kept for an additional period of 5 (five) years, with the specific purpose of producing evidence or for a period longer than that defined herein, for the purpose of compliance with legal or regulatory obligations by APOLOPAG.

5.6.3. The Personal Data related to USER’s access to APOLOPAG’s website and internet services may be stored by APOLOPAG for up to 6 (six) months, in accordance with current legislation.

5.6.4. Anonymized information that does not identify the respective holders, may be stored indefinitely for statistical purposes.

5.6.5. APOLOPAG applies advanced security standards, including firewalls, antivirus, and other software that help protect against hacking or leakage of stored personal data. Although APOLOPAG is dedicated to protecting the platform, the user is responsible for protecting and maintaining the privacy of their registration and personal data. APOLOPAG is not responsible for personal data that the user shares with third parties.  Although APOLOPAG is dedicated to protecting the Platform, the USER is responsible for protecting and maintaining the privacy of their registration and Personal Data. APOLOPAG is not responsible for Personal Data shared by the user with third parties.

5.6.6. To the extent of the applicable legislation, APOLOPAG is not responsible for illegal violations of its platform that may compromise its database and the USER’s Personal Data, and is not responsible for the misuse of the Personal Data obtained on the platform fraudulently or unlawfully.

5.6.7. In case of suspicion or confirmation of the platform’s violation or loss of USER’s Personal Data, APOLOPAG will make its best efforts and take immediate measures to eliminate or reduce the risks of damage to the user, as well as inform potentially affected users and the competent authorities of such fact, as well as the risks involved and the measures adopted to avoid such damage.

5.7. Amendments to the Privacy Policy

5.7.1. This policy will be periodically reviewed by APOLOPAG to adapt it to the provision of services to the user, by deleting, modifying or inserting new clauses and conditions and will be informed to the user, and the updated version may be consulted at any time by the user, by accessing the link:

5.7.2. If the USER does not agree with the changes, they may request the cancellation of their registration with APOLOPAG.

5.7.3. The completion of the registration or continuity of utilization of the platform and services from APOLOPAG by the USER will be interpreted as agreement and acceptance of the current version of the policy, including the last changes made, which are now fully applicable.

5.8.  USER’s Rights

5.8.1. The user is allowed, at any time, within the limits of the applicable data protection legislation, to exercise the rights of: (i) confirmation of the existence of processing of personal data of that user; (ii) access to personal data; (iii) correction of incomplete, inaccurate or outdated personal information; (iv) anonymization, blocking or deletion of unnecessary, excessive or treated in non-compliance with the provisions of; (v) portability of personal data to another service provider upon express request and observing the commercial and industrial secrets of APOLOPAG, in accordance with the regulations of the competent authority; (vi) elimination of personal data processed based on the user’s consent, except in the exceptions provided for in applicable legislation; (vii) The information of the public and private entities with which APOLOPAG has; (viii) information on the possibility of not providing consent and on the consequences of refusal, when a certain treatment operation is based on the user’s consent; and (ix) the revocation of consent, in the Agreements of the applicable legislation. In case of elimination of their Personal Data, as referred to in item 9.1. (vi) above, the USER will not be able to use the APOLOPAG System.

5.8.2. The rights may be exercised by sending a written request from the USER, accompanied by proof of identity, to the address indicated in the preamble of the policy, addressed to APOLOPAG’s data protection officer.

5.8.3. APOLOPAG may contact the USER to confirm their identity before the fulfillment of the request, which will only be approved upon confirmation of the USER’s identity.

5.9. Clarification of Questions

5.9.1. Any questions regarding this Policy or requests concerning USER rights can be sent to APOLOPAG’s Data Protection Officer via email at [email protected], or directly on the website at

5.10. Clarification of doubts

5.10.1. Any questions regarding this policy or the requests regarding the USERS’ rights may be sent to APOLOPAG’s Data Protection Officer on the website, or at the address of APOLOPAG’s head office.


6.1. The USER shall not perform the following actions due to or through the use of the Website and/or APOLOPAG Services under penalty of civil and criminal liability:

(i) any unlawful acts and/or violation of current legislation, including the provisions of Law No. 9.613/98; and

(ii) any acts that, directly or indirectly, in whole or in part, may harm the Website or APOLOPAG and/or any partners.

(iii) acts contrary to moral and good behavior;

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

(v) acts that cause or lead to contamination or harm 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 APOLOPAG Services for the purpose of committing any type of fraud that harms the Website, APOLOPAG, or any third party;

(vii) engage in any actions that directly or indirectly, in whole or in part, may cause harm to APOLOPAG, its Affiliates, an User and/or any third party; and

(viii) use any corporate name, trademark, domain name, slogan or advertising expression or any distinctive sign or intellectual property owned by APOLOPAG and/or its Affiliates.


7.1. The User is solely responsible:

(i) for the veracity and updating of all User Information;

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

(iii) for repairing any and all damages, direct or indirect (including arising from a violation of any rights of other users, third parties, including intellectual property rights, confidentiality, and personality), that are caused to APOLOPAG, or, even, to any third party, including by virtue of non-compliance with the provisions of this policy or any act practiced from your access to the Internet, the Website and/or Features, as the case may be.

7.2 The User will have the right to freely consult the form and all content of their personal data stored in APOLOPAG’s database and to always have their consent to the use of User Information for purposes other than those already provided for in this document. The deadline for providing this information will be informed after the request.

7.3: Under no circumstances will APOLOPAG be responsible for:

(i) for any and all acts of omission performed by the User arising from the access to the website and/or the features;

(ii) for the misuse of the Website and/the Features by any User;

(iii) for partners/third parties links and website(s), the User is subject to terms of use and privacy policies of the respective website(s);

(iv) for failures, technical impossibilities or unavailability of APOLOPAG system and/or Features due to the fault of the user, of third parties, fortuitous event or force majeure; and

(v) for the installation on the User’s or third party’s devices of viruses, trojans, malware, worm, bot, backdoor, spyware, rootkit, or by any other devices that may be created, as a result of the User browsing the internet.

7.4. APOLOPAG may, by itself or through third parties, at any time and for any reason, in its sole discretion, without the need for any prior or subsequent notice or notification to any User, without prejudice to initiating appropriate legal measures, suspend or limit the use of APOLOPAG Services and/or access to the Features, close the account of any user, at any time, in the Features and/or take other measures that deem necessary for compliance with this Policy and for the proper functioning of the Website and/or the Features.

7.5. APOLOPAG may also suspend or limit the use of APOLOPAG Services and/or access to the Features, close the account of any User in the event of non-compliance with the terms of this Policy and non-compliance with a legal obligation, and refusing to open an account and/or register for the use of its services.


8.1. APOLOPAG owns:
(i) any and all software or Features used in the provision of APOLOPAG Services;
(ii) the Features’ visual identity (including the graphic-visual art design 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 may not be used, by any means by the User.


9.1. The tolerance for not complying 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 forgiveness, or amendment of what is herein provided.


10.1. This Policy’s effective date starts on the date of its publishing on the APOLOPAG’s website, with a date set forth in the preamble to this Policy, ending on the date on which the Policy is unilaterally amended or updated by APOLOPAG. Any change and/or update of this Policy will take effect from the date of its publication on APOLOPAG’s website and/or in the Features, as the case may be, and must be fully observed by the user regardless of notification.

10.2. APOLOPAG, at any time, in its sole discretion and without the need for any prior or subsequent notice to any User or thir party may:

(i) suspend, cancel or interrupt APOLOPAG Services and access to the Features and
(ii) remove, change and/or update in whole or in part APOLOPAG Services and/or Features, as well as their respective content and/or this Policy.


11.1. This policy is governed by Brazilian law. Any disputes or controversies arising from any actions carried out in the context of the use of APOLOPAG Services and/or Features by the User, including regarding the non-compliance with the terms of this Policy or the violation of APOLOPAG, other Users, and/or third parties rights, including intellectual property rights, confidentiality, and personality, will be resolved in the Comarca of Maringá, State of Paraná to the detriment of another, however privileged.