Effective as of September 18th, 2020


This LGPD Disclosure reflects the parties’ agreement on the terms governing the processing of certain data in connection with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais) (“LGPD”). The provisions of this LGPD Disclosure are effective solely to the extent the LGPD applies, anything not declared here are subject to Linkfire’s Privacy Policy.

Definitions and Interpretation

In this LGPD Processor Addendum:

Brazilian Customer Personal Data” means personal data that is processed by Linkfire on behalf of Customer.

The terms “controller”, “data subject”, “personal data”, “processing” and “processor” as used in this LGPD Disclosure have the meanings given in the LGPD.

Capitalized terms used but not defined in this LGPD Disclosure will have the meanings set out in the Privacy Policy.

If this LGPD Disclosure is translated into any other language, and there is a discrepancy between the English text and the translated text, the English text will govern.

Personal information collected and processed

Section 5 of our Privacy Policy sets forth the categories of personal information that Linkfire collects and processes about you, a description of each category, and the sources from which we obtain each category.

While both the GDPR and the LGPD protect any information relating to an identified or identifiable natural person, unlike the GDPR, the LGPD does not give a detailed definition of what kind of information it refers to, making its scope very broad.

Processing of Data

Linkfire’s Compliance with Instructions. Linkfire will comply with the data controller’s written instructions unless applicable laws to which Linkfire is subject require other processing of Brazilian Customer Personal Data by Linkfire.

Territorial scope

Both the GDPR and the LGPD have an extraterritorial reach: they apply to all companies offering goods or services to data subjects in the EU or Brazil, regardless of where they are located.

The LGPD will also not apply to data flows that originate outside of Brazil and are merely transmitted, but not further processed in the country.

Data Subject Rights

Responses to Data Subject Requests. If Linkfire receives a request from a data subject in relation to Brazilian Customer Personal Data, Linkfire will:

(a) if the request is made via a Data Subject Access Request, respond directly to the data subject’s request in accordance with the standard functionality of that Data Subject Access Request; or

(b) if the request is not made via a Data Subject Access Request, advise the data subject to submit his/her request to Customer, and Customer will be responsible for responding to such request.

Changes to this LGPD Disclosure

Linkfire may change this LGPD Disclosure from time to time, without notice, if the change is required to comply with applicable law, applicable regulation, a court order or guidance issued by a governmental regulator or agency.