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GARNET

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Privacy Policy

Last updated ·

This Policy explains how we process the personal data of people who visit garnet.finance and of people who contact us through the channels listed on it, in accordance with Brazil's General Data Protection Law (Law No. 13,709/2018, the “LGPD”). The site is operated by Garnet Inovação Digital Ltda. (“Garnet”), registered under CNPJ No. 49.456.581/0001-60.

Who we are

Garnet is the controller of the personal data processed through this site. We connect institutional clients to the digital asset market with OTC trading, liquidity, settlement and treasury solutions.

For any matter related to this Policy or to your data, contact us at contato@garnetbr.com or by phone and WhatsApp on +55 11 94050-1364.

What data we process

This is an institutional site: it has no sign-up, no logged-in area and no forms that store information. In practice, we process:

  • Browsing data — IP address, date and time of access, pages visited, browser and device type — recorded automatically by the infrastructure that hosts the site.
  • Your language preference, kept in an essential cookie. See the Cookie Policy.
  • Contact data: when you write to us on WhatsApp or by e-mail, we receive whatever you choose to share, such as your name, phone number, e-mail, company and the content of your message.

The quote simulator runs entirely in your browser: the amounts you type are not sent to Garnet. They only reach us if you choose to send the pre-filled WhatsApp message.

The market prices shown are fetched by our servers from market data providers, such as Binance and CoinGecko, without sending any of your data.

Why we use it

Purpose
Running the site, keeping it secure and preventing fraud and abuse
Data
Browsing data
Legal basis (LGPD)
Legitimate interest (art. 7, IX) and compliance with a legal obligation (art. 7, II), including the retention of access logs required by Brazil's Internet Civil Framework
Purpose
Remembering your language
Data
Language cookie
Legal basis (LGPD)
Legitimate interest (art. 7, IX)
Purpose
Answering contacts, quote requests and enquiries
Data
Contact data
Legal basis (LGPD)
Pre-contractual steps at your request (art. 7, V) and legitimate interest (art. 7, IX)
Purpose
Complying with legal and regulatory obligations and exercising rights in proceedings
Data
The data each case requires
Legal basis (LGPD)
Compliance with a legal or regulatory obligation (art. 7, II) and the regular exercise of rights (art. 7, VI)

We do not sell personal data, we do not use it for advertising and we do not make automated decisions about you based on it.

Client relationships

If you or your company become a client, onboarding involves identification and verification (KYC/KYB) and anti-money-laundering and counter-terrorist-financing procedures required by applicable law — including Brazilian Law No. 9,613/1998 and Law No. 14,478/2022 on virtual asset service providers. That processing is described in the contractual documents and notices provided during onboarding.

Who we share it with

We share data only when necessary, with:

  • Technology providers that help us run the site and our communications — hosting, cloud infrastructure, e-mail and messaging —, who process data on our behalf or under their own policies;
  • Public authorities, regulators and courts, when required by law or regulation or ordered by a competent authority;
  • Professional advisers — legal, accounting and audit —, bound by confidentiality.

When you click a WhatsApp link, you are taken to a third-party service (Meta), subject to WhatsApp's own terms and privacy policy.

International transfers

Some of our providers may store or process data outside Brazil. In those cases we apply the safeguards set out in art. 33 of the LGPD, such as specific contractual clauses and the choice of providers with adequate data protection standards.

How long we keep it

  • Site access logs: 6 (six) months, as required by Brazil's Internet Civil Framework (Law No. 12,965/2014), unless a longer period is required by law or court order.
  • Contacts and conversations: as long as needed to handle your request and maintain the relationship, observing statutory limitation periods.
  • Client data: for the periods required by law — for anti-money-laundering records, at least 5 (five) years after the relationship ends.
  • Language cookie: 1 (one) year, or until you delete it in your browser.

After these periods, the data is deleted or anonymised.

Security

We apply technical and organisational measures to protect data against unauthorised access and accidental or unlawful loss, alteration or disclosure — such as encrypted connections (HTTPS), access controls and providers with recognised security standards.

No system is entirely free of risk. If a security incident may result in relevant risk or harm, we will notify you and Brazil's National Data Protection Authority (ANPD), as required by the LGPD.

Your rights

Under art. 18 of the LGPD, you may request at any time:

  • confirmation that we process your data, and access to it;
  • correction of incomplete, inaccurate or outdated data;
  • anonymisation, blocking or deletion of unnecessary or excessive data, or data processed in breach of the LGPD;
  • portability of your data to another provider, subject to commercial and industrial secrets;
  • deletion of data processed on the basis of your consent, and withdrawal of that consent, where applicable;
  • information about the entities we share data with;
  • objection to processing based on legitimate interest, where it breaches the LGPD.

To exercise your rights, write to contato@garnetbr.com. We may ask for information to confirm your identity and will reply within the legal deadlines. Some data may have to be kept after a request when a legal or regulatory obligation applies. You may also lodge a complaint with the ANPD. If you are outside Brazil, you may have additional rights under your local law — contact us and we will help.

Data protection officer

You can reach Garnet's data protection officer (encarregado) at contato@garnetbr.com.

Children and teenagers

Our services are intended for companies and for people aged 18 or over. We do not knowingly collect data from children or teenagers.

Changes to this Policy

We may update this Policy to reflect changes to the site, to our practices or to the law. The current version will always be on this page, with the date of the last update at the top.