Welcome to Banlek!
Banlek is committed to your privacy and has prepared this Privacy Policy (“Policy”) so that you understand how we protect your data, how it is used, and what your rights are regarding it.
This Policy is therefore intended for:
- Photographers who register to sell their photos on Banlek;
- Users of Banlek websites or social media;
- Citizens whose photos are sold on the Banlek website.
Who is Banlek?
BANLEK SERVIÇOS AUDIOVISUAIS LTDA. is a photography startup that connects photographers and clients for online photo sales, registered under CNPJ No. 34.299.202/0001-06 and located at Estrada do Cantagalo, 3000 / 91, in the Cuiabá neighborhood, Petrópolis, RJ.
Whenever you find throughout this Policy the terms “Banlek,” “we,” “our,” or “us,” we are referring to BANLEK SERVIÇOS AUDIOVISUAIS LTDA.
Important definitions
You may come across terms such as “controller,” “operator,” “processing,” among others. Therefore, below are some definitions you should keep in mind to better understand this Policy.
Controller means the party responsible for the Processing of Personal Data, who makes the decisions regarding such Processing. Please note that it is possible for two parties involved in the Processing to be jointly responsible and, in that case, they will be considered co-controllers, and each Controller will assume, within the limits of its role, responsibility for the processing it performs.
Operator means the party responsible for carrying out processing activities on behalf of the Controller, that is, following its instructions.
Processing means any operation performed with personal data, such as collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.
Therefore, not all processing carried out by Banlek applies to you. Everything will depend on how you interact with us.
How can you exercise your rights under the General Data Protection Law (“LGPD”)?
According to the LGPD, you have the following rights regarding your personal data:
- Confirmation of the existence of processing;
- Access to personal data;
- Correction of incomplete, inaccurate, or outdated personal data;
- Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
- Data portability, upon express request, subject to commercial and industrial secrets;
- Deletion of personal data processed based on consent;
- Information about public and private entities with which we may share personal data;
- Information about the possibility of not providing consent and the consequences of refusal;
- Revocation of consent;
- Filing a complaint regarding your personal data against Banlek before the Brazilian National Data Protection Authority (“ANPD”). However, please remember to contact us before filing any complaint with the ANPD. We will be pleased to assist you and resolve your request quickly and simply.
To exercise any of the rights listed above, or if you have any questions regarding this Privacy Policy, please contact our DPO by filling out the form on our Data Subject Rights portal access here
Who is Banlek’s Data Protection Officer or DPO?
Our DPO is Beatriz Martins, with Marcelo Polachini Pereira serving as alternate. Both may be contacted by filling out the data subject rights request form above.
What personal data may we process and how?
We may collect or receive your personal data directly from you through our website, app, social media, forms, surveys, registrations, and contracts signed with us, among others; or from third parties authorized to share your personal data with us.
Banlek does not allow the upload, disclosure, or sale of unauthorized photographs. Only images produced in accordance with applicable law may be uploaded to the platform, especially regarding image rights and the protection of the personal data of the individuals portrayed in them. Any content that violates these rights will be removed immediately and may result in the suspension or exclusion of the responsible photographer, without prejudice to any applicable legal liabilities.
Thus, we may Process both your basic identification data, such as full name, ID card, CPF, date of birth, profession, address, image, as well as your biometric data, as explained in more detail below.
Registration – If you are a freelance photographer and wish to register with Banlek to sell your photos, we may process registration data as necessary, such as full name, CPF, phone number, email, bank details, address, social media profile, among others.
Access to photos – If you wish to access your photos, we may request, for your privacy, a selfie to perform facial recognition using biometrics. But don’t worry! Your selfie and biometric data will be used exclusively to allow you to identify your own photo. As soon as the images corresponding to your face are located, both the selfie and the biometric data used to retrieve the images will be immediately and automatically discarded securely.
Purchase of photos – If you wish to buy your photos, we may request your identification data, such as full name and CPF, and the financial data necessary to process the payment, such as credit card information.
Visit to our website – If you are only visiting our website, we may use log files. These files record users on the website, and the information contained in them includes internet protocol (IP) address, browser type, internet service provider (ISP), date/time, referring/exit pages, and possibly the number of clicks, overall and by feature. This information is used to analyze trends, track user movement around the website, and gather demographic information. IP address and other information are not linked to any personally identifiable information.
Contact us through the website – If you want to contact Banlek for information about event photos through the form available on the website, we will Process your full name, phone number, and email address.
Financial transactions – To operate and maintain the service and other third-party products and services offered through the website, we may use, for example, personal data to fulfill your bookings and purchase requests, including payment processing and your location.
Cookies – To personalize your experience with us, adapting the content or experiences we show you, we may collect analytics and marketing cookies, provided you consent, and necessary cookies regardless of your consent.
User Support – If you have any questions of any kind, you may contact us through our customer service. In that case, we may need to request some of your personal data to handle, investigate, respond to, and resolve complaints and possible issues.
Communications and marketing – When you interact with Banlek in some way, we may send institutional and promotional communications and email marketing, but you will always have the option to unsubscribe.
Location – We may Process your location data to fulfill a real-time Photographer request or if the website itself collects information about your location.
Research and development - For research, analysis, record-keeping, and reporting purposes; to develop and test new products, features, and ideas; to learn about our customer base; and to evolve and improve the PLATFORM;
Security and Investigations - We use your information to maintain the security of the website, including to verify your identity, perform credit checks, investigate or prevent possible fraud or other violations of our Terms of Use or this Privacy Policy and/or in connection with possible attempts to harm Users or third parties;
For what purposes and based on which legal grounds do we Process your personal data?
Aware of the importance of your privacy and personal data protection, Banlek is committed to Processing your personal data in compliance with the principles of the LGPD and with the proper legal basis, as applicable in each case.
Thus, the legal bases for carrying out the Processing of your personal data may be the following:
- Performance of a contract with you
- Guaranteeing fraud prevention and data subject security in identification and authentication processes for registration in electronic systems
- Compliance with legal or regulatory obligation or regular exercise of our rights
- Our legitimate interest
- Your consent
- Third-party personal data
Cookies
Cookies are data packets sent by our servers and stored on users' devices. This data enables better performance and optimization of the user experience on our website. These cookies may also be used to measure website performance, provide metrics, assess areas requiring improvements or optimizations, and understand how the service is being used by users.
At Banlek, we use different browser storage technologies to provide users with a stable and personalized experience.
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Local Storage (localStorage and sessionStorage)
On our website and in logged-in areas, we mainly use the browser's localStorage and sessionStorage to:- Store the user's login token, allowing the session to remain active;
- Remember preferences, such as language and navigation options;
- Optimize the experience of using the platform.
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Strictly necessary cookies (photographer dashboard only)
In the administrative area intended for photographers, we use session cookies considered strictly necessary to:- Secure authentication;
- Session maintenance during use;
- Proper functioning of internal dashboard resources.
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Third-party cookies (when applicable)
We may occasionally use third-party cookies, such as Google Analytics or Google Ads, to:- Analyze browsing statistics;
- Assess platform performance;
- Display relevant advertisements to the user.
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User management
The user may, at any time, delete or block cookies and local browser storage data. However, deleting the login token or strictly necessary cookies will end the session and require a new login.
We will use cookies based on our legitimate interest, but if you object to their use, you may remove them from your browser or device, except for strictly necessary cookies, which are essential for the correct functioning of the website.
Processing of children's personal data
We believe it is important to provide additional protection for children online and encourage parents and legal guardians to spend time online with their children to observe, participate in, and/or monitor and guide their activities.
Banlek does not commercialize photos of children unless their parents or legal guardians have provided prior consent or, preferably, requested a photo. If you, as a parent or legal guardian, believe that Banlek has non-consented images of children in its database, please immediately contact our DPO and we will remove the images from our databases.
The assessment of the case may, however, lead to the need to retain the data in the event of indications of unlawful activity. In such cases, instead of data deletion, the data may be forwarded to the competent public authority.
International transfer of personal data
Your personal information may be transferred to and processed in countries other than the country in which you reside. Our servers are located in the United States and our Group companies, as well as their service providers and third-party partners, operate worldwide. This means that when we collect your personal information, we may process it internationally.
However, we take appropriate precautions to require that your personal information remains protected in accordance with this Privacy Policy. This includes the implementation of Brazil's standard contractual clauses for transfers of personal data between Group companies, which require all of them to protect personal data for which they are Controllers in Brazil, in accordance with Brazil's data protection laws.
Retention of personal data
We retain the personal information we collect from you when we have an ongoing legitimate business, legal, or contractual need to do so (for example, to provide a service you requested or to comply with applicable legal, tax, or accounting requirements). This does not mean that the information will always remain available. Collection does not create a duty of indefinite storage, availability, and delivery of collected data.
When we no longer have an ongoing legitimate business, legal, or contractual need to process your personal information, we will delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store the personal information and isolate it from any further processing until deletion becomes possible or unnecessary.
Changes to the Privacy Policy
This Privacy Policy may be revised by Banlek at any time, which is why we recommend that you visit this Policy periodically to stay updated on how we process your personal data.