Privacy Policy
Welcome to Banlek!
Banlek is committed to your privacy and the protection of your personal data. For this reason, we have prepared this Privacy Policy (“Policy”) to explain, clearly and transparently, how we process personal data, for what purposes it is used, with whom it may be shared, and what your rights are.
This Policy is intended, especially, for:
Photographers who register to sell their photos on Banlek;
Users of Banlek’s websites, applications, platforms, or social networks;
People who purchase photographs through Banlek;
People portrayed in photographs made available on the Banlek platform; and
Other individuals who interact with us and whose personal data may be processed by Banlek.
Not all processing operations described in this Policy apply to you. This will depend on how you interact with Banlek and our services.
1. Who is Banlek?
BANLEK SERVIÇOS AUDIOVISUAIS LTDA., registered under CNPJ No. 34.299.202/0001-06, headquartered at Estrada do Cantagalo, 3000 / 91, Cuiabá neighborhood, Petrópolis/RJ, Brazil, is a photography startup that connects photographers and customers for the online sale of photos.
Whenever you find the terms “Banlek”, “we”, “our”, or “us” throughout this Policy, we will be referring to BANLEK SERVIÇOS AUDIOVISUAIS LTDA.
2. Important Definitions
To facilitate the understanding of this Policy, we present some concepts provided for in data protection legislation:
Personal Data: any information related to an identified or identifiable natural person.
Sensitive Personal Data: personal data concerning racial or ethnic origin, religious conviction, political opinion, affiliation to a union or organization of a religious, philosophical, or political nature, data concerning health or sex life, genetic or biometric data, when linked to a natural person.
Controller: natural or legal person who is responsible for decisions regarding the processing of personal data.
Processor: natural or legal person who processes personal data on behalf of the Controller and in accordance with their instructions.
Processing: any operation performed with personal data, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation, modification, communication, transfer, dissemination, or extraction.
Data Subject: natural person to whom the personal data being processed refers.
3. What is Banlek’s role in processing personal data?
Banlek may act as Controller when it is responsible for defining the essential purposes and means of processing, as occurs, for example, in the processing of data related to registration and platform use, transaction execution, user support, platform security, and compliance with legal obligations.
The photographs made available on the platform are produced and uploaded by registered photographers. The responsibility for the lawfulness of capturing and making images available must observe applicable legislation, Banlek’s Terms of Use, and other conditions applicable to the relationship between Banlek and photographers.
Regarding the images made available by photographers on our website, Banlek acts as an independent Controller. This means you can request the removal of your photo directly from us.
Regardless of the classification applicable to each operation, Banlek adopts measures designed to ensure that personal data processed through its platform is used in compliance with applicable legislation.
4. How do we obtain your personal data?
We may obtain your personal data:
Directly from you, when you register, use our services, purchase photographs, contact us, use our website, or provide information through other means;
Automatically, during the use of our websites and platforms, through access logs, cookies, and similar technologies;
From photographers registered on the platform, especially when photographs produced by them are made available for search and purchase through Banlek.
This means that, in certain situations, we may process your image even if you have not registered or interacted directly with us, since the photographs made available on the platform are provided by registered photographers.
Banlek does not authorize the availability or sale, through its platform, of photographs produced or used in non-compliance with applicable legislation, especially regarding personality rights, image rights, and personal data protection of portrayed individuals.
If you identify a photograph that you believe has been improperly made available, you may contact us through the channel indicated in this Policy.
5. What personal data do we process, for what purposes, and on what legal bases?
The personal data processed will depend on your relationship and interaction with Banlek.
Photographer Registration
If you are a photographer and wish to use Banlek to sell your photographs, we may process data such as full name, tax ID (CPF), phone number, email, address, bank details, social media profiles, and other information necessary for registration and service provision.
Purposes: enable your registration, manage your account, allow the use and provision of services offered by the platform, process payments, and comply with obligations arising from the relationship established with us.
Legal base: performance of a contract or preliminary procedures related to a contract and, where applicable, compliance with a legal or regulatory obligation.
Photograph Search via Facial Recognition
If you use the photograph search feature via facial recognition, we may request a selfie, which will be used to generate and compare biometric information with the photographs available on the platform.
The purpose of this operation is strictly to allow the location of photographs matching the person who conducted the search.
The selfie and the biometric data generated to perform the search are not used for permanent user authentication and, once the search operation is complete, are immediately and automatically discarded in a secure manner, according to the tool’s operation.
Legal base: fraud prevention and data subject safety in identification and authentication processes for electronic system registration, under applicable legislation.
Purchase of Photographs
When you purchase photographs through the platform, we may process information such as full name, tax ID (CPF), and other data necessary to complete the purchase.
Payment-related data may be processed by Banlek and/or specialized providers responsible for processing the transaction, such as Mercado Pago, PayPal, and Asaas, whose sharing occurs via integration.
Purposes: process the purchase, issue charges and payments, issue tax documents, prevent fraud, and comply with legal and contractual obligations.
Legal bases: performance of a contract, compliance with a legal or regulatory obligation.
Navigation and Use of the Platform
When you access our websites and platforms, we may process technical information and logs related to service usage, such as your IP address, access date and time, browser and device type, accessed pages, features used, interaction logs, and information related to platform operation and security.
Purposes: enable service operation, maintain access logs, analyze platform performance, identify flaws, improve our services, and ensure environment security.
Legal bases: compliance with a legal or regulatory obligation and legitimate interest of Banlek, as applicable.
Contact and Support
When you contact us, including through the rights exercise form or our customer support, we may process your name, phone number, email, and other information provided during service.
Purposes: answer questions, provide support, investigate and solve problems, receive complaints, and address requests.
Legal bases: performance of a contract or preliminary procedures, legitimate interest, and/or regular exercise of rights, depending on the request context.
Communications and Marketing
We may use your contact data to send communications related to Banlek’s services and, where applicable, promotional communications.
Marketing communications will observe the legal basis appropriate to the context and offer a mechanism so you can opt out of promotional messages at any time.
Legal base: legitimate interest of Banlek.
Research, Development, and Service Improvement
We may use information related to platform usage to conduct analyses, produce reports, develop and test new features, understand service usage, and improve user experience.
Whenever possible and suitable for the purpose, we will use aggregated or anonymized data.
Legal base: legitimate interest of Banlek, subject to the rights and legitimate expectations of data subjects and the principles of necessity, transparency, and proportionality.
Security, Fraud Prevention, and Exercise of Rights
We may process information to maintain platform security, verify identities, prevent and investigate fraud, terms violations, unauthorized use attempts, and other potentially unlawful conduct.
We may also retain and use information when necessary to exercise or defend Banlek's or third parties' rights in judicial, administrative, or arbitration proceedings.
Legal bases: legitimate interest, regular exercise of rights, compliance with legal/regulatory obligations, and specific exceptions under Article 11 of the LGPD for sensitive personal data.
6. Who do we share personal data with?
Banlek may share personal data when necessary for service provision, platform operation, transactions, legal compliance, or exercise of rights.
Depending on the operation, data may be shared with:
Infrastructure, hosting, storage, and technology service providers;
Providers responsible for image recognition and processing features;
Financial institutions, acquirers, payment gateways, and processors;
Consultants, auditors, law firms, accounting firms, and professional advisors;
Partners necessary for providing contracted services;
Photographers, if you enable the feature to display your phone number to the platform;
Public, judicial, administrative, or regulatory authorities upon legal obligation or valid determination.
Banlek limits sharing to necessary data and contractually requires providers to adopt adequate security and privacy measures.
7. How do we protect your personal data?
Banlek adopts technical, administrative, and organizational measures to protect personal data against unauthorized access, accidental/unlawful destruction, loss, alteration, or improper disclosure. These include:
System and information access controls;
Authentication mechanisms and permission management;
Technological infrastructure security measures;
Internal privacy and information security procedures;
Incident identification, containment, and response procedures.
8. Cookies and Similar Technologies
We use cookies and browser storage to operate the platform, maintain sessions, save preferences, and analyze performance/deliver tailored content.
Local Storage
We use localStorage and sessionStorage to:
Store login tokens and maintain active sessions;
Remember language and navigation preferences;
Optimize platform experience.
Strictly Necessary Cookies
In the photographer admin area, necessary cookies enable secure authentication, session maintenance, and dashboard functionality.
Analytical, Advertising, and Third-Party Cookies
Where applicable, third-party analytics/advertising tools are used only after user consent, which can be managed or revoked at any time via browser settings.
9. Processing of Children and Adolescents' Personal Data
Banlek provides special protection for minors' data. Processing requires specific, prominent consent from at least one parent or legal guardian when legally required. Unauthorized images of minors can be reported for removal to our DPO.
10. International Data Transfer
Due to our technology infrastructure, your personal data may be stored or processed outside Brazil, currently including servers located in the United States.
11. What are your rights?
Under the LGPD, you may request access, correction, anonymization, blocking, deletion, data portability, information on shared data, consent revocation, and review of automated decisions.
12. How to exercise your rights?
Contact Banlek's DPO via the form on our Data Subject Rights Portal. Identity confirmation details may be required.
13. Data Protection Officer (DPO)
DPO: Letícia Souza | Alternate: Marcelo Polachini Pereira. Contact via the Data Subject Rights Portal form.
14. Policy Updates
This Policy may be updated periodically. Check back regularly for the latest version.
BANLEK SERVIÇOS AUDIOVISUAIS LTDA.
CNPJ No. 34.299.202/0001-06