Privacy Notice / South Africa
Last Update: October 2026 Previous version
PRIVACY NOTICE: WEBSITE, CUSTOMERS, PROVIDERS, END-USERS AND SUB-MERCHANTS
THIS IS THE PRIVACY NOTICE OF DLOCAL AND ITS SUBSIDIARIES ESTABLISHED WITHIN SOUTH AFRICA
This Privacy Notice explains how we process personal information about (i) visitors to our Website, (ii) representatives of our Customers and other business contacts who use our Merchant Dashboard or interact with us, and (iii) in certain cases, End-Users and Sub-Merchants who benefit from or are involved in the services we provide to our Customers, except for the limited situations described in this Privacy Notice where we act as an independent data controller
Your privacy is very important to us. We are committed to the protection of your personal information, and the purpose of this Privacy Notice is to inform you about the way we process your personal information, including references to which information we process, how, why, and for how long, together with information about your rights as a Data Subject.
This Privacy Notice (together with our Terms and Conditions available on our website, any product‑specific or service‑specific terms and conditions that may be made available to you from time to time, and any other documents referred to in it) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. This Privacy Notice also sets out how you can instruct us if you prefer to limit the use of that personal information, as well as the procedures that we have in place to safeguard your privacy.
It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. This Privacy Notice supplements the other notices and is not intended to override them.
1. IMPORTANT INFORMATION
dLocal and its subsidiaries in South Africa are separate data controllers but are collectively referred to in this Privacy Notice as “dLocal”, “we” or “our” or “us”. The reference to “data controller/processor” means the same as “responsible party” and/or “operator” in terms of the Protection of Personal Information Act, 2013 (“POPIA”). For the avoidance of doubt, data controller means responsible party, and data processor means operator, as defined in the POPIA.
In summary, we generally act as a responsible party in relation to Website visitors and representatives of our Customers and other business contacts. For most End-User and Sub-Merchant data, we act as an operator on behalf of the relevant Customer, except for the limited situations described in this Privacy Notice where we act as an independent responsible party (for example, for certain fraud-prevention and compliance activities).
The responsible party for processing described in this Privacy Notice is dLocal, and its South African subsidiary, Depansum (Pty) Ltd, Unit G05, Century Gate Office Park, Century City, Milnerton.
Our Information Officer in South Africa is Agustin Cerisola, contact: [email protected], P O Box 1712, Milnerton, Western Cape, 7435. Our Promotion of Access to Information Act Manual (“PAIA Manual”) is available here and explains how to make an access request.
Individuals from whom we collect personal information (the “Data Subjects”)
In this Privacy Notice, “you” or “your” means an individual who is the subject of personal information we process as a data controller, which would typically be: (i) the visitors of our website at www.dlocal.com (our “Website”); (ii) the representatives of merchants and other payment providers (our “Customers”) who interact with us and access our Merchant Dashboard to receive our payment processing services; (iii) representatives of third party service providers who interact with us to fulfil their contractual obligations with us; (iv) representatives of prospective Customers whose business contact details we obtain from third‑party sources such as business‑contact databases, sales intelligence or lead‑generation platforms; and (v) representatives of partners, vendors, counterparties and other organisations who interact with us in connection with our commercial, operational, contractual or vendor management activities.
In addition, we act as a data controller in relation to personal information about buyers or beneficiaries of our Customers (“End-Users”) as well as business customers of our Customers who use our dLocsl for Platforms solution (our “Platform product”) (“Sub-Merchants”). Our Platform product enables marketplaces to onboard and manage their own Sub-Merchants while using our services to process payments and payouts for those sellers. We process this personal information only for the for limited purposes described in section 3 of this Privacy Notice. References to “Sub-Merchants” in this Privacy Notice should be understood in this sense.
For most End-User and Sub-Merchants’ personal information, we act as a data processor on behalf of the relevant Customer, except for the limited situations described in this Privacy Notice where we act as an independent data controller, including for certain fraud prevention, compliance and regulatory purposes.
Where an End-User chooses to save a payment method with a Customer that uses dLocal’s services, we may process the relevant payment credential or token, payment-method identifiers, transaction information, technical data and records of the End-User’s authorisation. We process this information to enable the Customer to initiate future subscription or other recurring payments in accordance with the terms agreed between the End-User and the Customer. The Customer is responsible for providing the End-User with its own privacy notice and, where required, obtaining the End-User’s consent or other valid authorisation for the saving and use of the payment method.
For the purpose of this Privacy Notice, “Data Protection Legislation” means the Protection of Personal Information Act (POPIA) 2013 and any other data protection legislation applicable within South Africa. Legal terms related to data protection used in this Privacy Notice follow the definition provided by the above-mentioned legislation.
2. INFORMATION WE MAY COLLECT (OR RECEIVE) ABOUT YOU
How is your personal information collected:
- Direct interactions. You may give us your Identity and Contact Data (as defined below) by filling in forms or by corresponding with us through available channels (for example, by email, through our online contact forms, or via our customer support tools such as Intercom), our CRM tools, our contract management tools, our project management tools, or other operational tools we use to manage our relationships and services. This includes personal information you provide as a representative of a Customer or a prospective Customer when you:
- apply for or enquire about our products or services;
- interact with us in connection with our services or our relationship with the Customer you represent;
- create a Customer user account on our payment processing service platform (“Merchant Dashboard”) to receive our services; or
- subscribe to our service or publications.
- Where you interact with us through those systems, we may also collect or generate records of those interactions, including communications, notes, comments, workflow or status information, and related metadata.
- Where we contact you as a representative of a prospective Customer and we have not obtained your personal information directly from you, we will usually do so using your business contact details that we have obtained from third‑party sources as described in section 2(f) below and will provide you with this Privacy Notice when we first contact you.
- Website and Merchant Dashboard usage. When you browse on our website or our Merchant Dashboard, we process Technical Data (defined below). We use certain strictly necessary Technical Data and cookies on the basis of our legitimate interests in making sure our Website and Merchant Dashboard work properly, including debugging, DDOS mitigation, and security. We may also use other cookies and similar technologies (for example, for analytics or personalisation) where you have given your consent through our cookie banner or preference centre; these help us improve the user experience and perform statistical analyses to optimise the quality of our Website and Merchant Dashboard. Please see our Cookies Policy HERE for further details, including how you can manage your cookie preferences.
- SmartFields, Mobile Checkout, Payment Links, Payout Links and Invoice Collection solutions, and our dLocal for Platforms solution (our Platform product). When you purchase goods or services from or receive payments to or from dLocal’s Customers using any of these solutions, you will most likely provide your personal information directly to dLocal, acting on behalf of those Customers.
In marketplace arrangements, we provide our services through our Platform product in combination with a Customer’s platform. Depending on our agreement with the Customer and the applicable data protection roles, Sub-Merchants and their End-Users may provide their personal information either directly to dLocal (for example, via dLocal-hosted onboarding and KYC/verification flows) or to the Customer’s platform (for example, via the Customer’s own user interfaces and onboarding tools). In the latter case, the Customer then shares that information with us so we can provide our services. - Static Virtual Accounts. In some markets, we also support Static Virtual Accounts (for example, fixed bank or cash virtual account numbers assigned to a particular Customer). In those cases, when you make a payment using a Static Virtual Account that has been allocated by a Customer using our services, we receive payment‑related information (such as the account/reference, amount, and timing of the payment) from the relevant payment channel in order to process and reconcile the transaction.
- Due Diligence. When you apply to become a Customer of dLocal or you operate as a Sub-Merchant under a dLocal Customer, we require that you provide personal information as detailed in this paragraph but not limited to this description. For regulatory reasons, we may request name, postal address, telephone number, and email address to fulfill our financial partners and regulatory requirements. We may also collect personal information about you, including financial data such as your ownership interest in the company, your status as a director or officer, your date of birth and government identifiers associated with you and your business (such as your social security number, tax number, or bank account information).
- Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources, including:
- providers of business‑contact databases, sales‑intelligence and outreach tools that lawfully collect and provide business contact details for B2B prospecting and outreach purposes; and
- providers we use to carry out fraud prevention checks, ID checks and other “Know Your Customer” checks we need to perform on our Customers’ representatives, Sub-Merchants and End users to comply with applicable financial services standards and requirements and to comply with applicable laws and regulations.
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
- Identity Data includes first name, last name, username, gender, date of birth, place of birth, nationality, job title and qualification, ID number, ID document (including document type and issuing/expiry dates), Income tax number;
- Contact Data includes billing address, delivery address, email address and telephone numbers, country and state of residence;
- Technical Data includes your internet protocol (IP) address, your login data, Google Analytics ID, internet browser and device type, time zone setting, location data and your use of our website, including which pages you visited, how you got to our Website, the time and length of your visit and your language preferences; it also includes device and online identifiers and related telemetry such as device ID, cookies and similar identifiers, browser user agent, geolocation, advertising ID, vendor ID, Android ID and similar identifiers used to help secure transactions and prevent fraud;
- Profile Data includes the username and password of our Customer’s representatives when they log in the Merchant Dashboard; and, for End‑Users and Sub‑Merchants, information about their account and interaction with our services, such as account creation date, purchase or transaction history (including total number and value of orders), first and last purchase dates, internal reputation or risk scores and similar information about how they use our services;
- Marketing and Communications Data includes your name, position and business details and includes your preferences in receiving marketing from us and our third parties and your communication preferences (including records of your communications with us, such as when you contact us for support or respond to our campaigns);
- Relationship, Engagement and Operational Data includes information about your professional relationship with us and your interactions with our services and teams, such as account history, deal or ticket information, meeting, call and email records, notes, comments, support messages, contract or project status information, activity history, and related metadata. Where relevant to our contract management and legal operations activities, it may also include contract and legal-intake information, workflow and approval status, assigned business contacts and roles, comments, deadlines, activity records, and access or permission attributes;
- Financial Data includes card data, bank account data, fiscal information and other payment‑instrument and payout information such as virtual or dynamic account numbers, wallet identifiers, payment method identifiers and related metadata, and beneficiary bank details (for example, beneficiary name, document or tax ID, bank name, branch and account number), as well as crypto or digital‑asset wallet addresses where relevant; and
- AI-tool interaction data may include queries and prompts, information retrieved from permitted records, excerpts, generated summaries, status or deadline flags, drafts, meeting briefings, data-quality suggestions, and related service or audit metadata. These materials may contain personal information that also appears in the underlying contract, intake, workflow or activity record
Our services are not directed at children (below 18). We do not intentionally collect children’s personal information. If we become aware that we have collected such information, we will delete it unless processing is permitted under the POPIA with competent person consent or another applicable ground.
We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information, but is not considered personal information in law, as this information will not directly or indirectly reveal your identity. Aggregated data collected include:
- Payment volumes and frequency
- Performance and risk metrics
- Merchant profitability and commercial analytics
- Aggregated views for external/merchant‑facing reports
- Compliance / AML & Data-Compliance metrics
3. HOW WE USE PERSONAL INFORMATION
We may process personal information for one or more grounds under POPIA section 11, including with your consent, to conclude or perform a contract with you, to comply with legal obligations, to protect your legitimate interests, or where processing is necessary for pursuing our legitimate interests (balanced against your rights). For activities such as due diligence, fraud prevention and identity verification, our lawful basis typically includes compliance with applicable law and legitimate interests.
3.1. Overview
In accordance with this Privacy Notice, dLocal may use your personal information in order to:
- provide the services you request from us (Lawful Basis: to comply with our legal obligations and performance of our contract with you);
- verify your identity or conduct appropriate checks for fraud (Lawful Basis: to comply with our legal obligations (for example under applicable KYC/AML, sanctions and financial‑services rules) and where necessary for our legitimate interests in detecting, preventing and investigating fraud, financial crime and abuse of our services and in protecting the security and integrity of our payment ecosystem);
- understand your needs in order to provide you with the products and services you require (Lawful Basis: performance of our contract with you);
- administer and manage our services, including billing for the services provided (Lawful Basis: performance of our contract with you, to comply with our legal obligations and necessary for our legitimate interests in operating and improving our services, ensuring accurate billing and internal record‑keeping, and pursuing and recovering fees and charges owed to us);
- distribute information, newsletters, publications and other communication via various mediums to keep you informed including direct marketing communications about our services that we send to representatives of existing and prospective Customers (which may include contacting you using business contact details obtained from third‑party providers such as business‑contact databases, sales‑intelligence or lead‑generation tools as described in section 2(f) above) (Lawful Basis: where required under applicable law, your consent, and otherwise performance of our contract with you and our legitimate interests in promoting and developing our business and managing our relationship with you and the Customer you represent);
- research and develop new services (Lawful Basis: performance of our contract with you and necessary for our legitimate interests in improving, developing and enhancing our products and services, understanding how they are used and ensuring they remain competitive and relevant);
- analyse customer and support interactions (including, where relevant, via our customer support tools such as Intercom and AI-powered analytics tools, including large language models) to understand product and support performance, identify common issues and improve our services (Lawful Basis: necessary for our legitimate interests in improving, developing and enhancing our products and services and ensuring good customer support);
- analyse information contained in our CRM, support, contract management, project management and other operational systems, including communications, notes, tickets, comments, statuses and related metadata, including with the help of AI-powered analytics tools (including large language models), to generate summaries, identify trends, support reporting and forecasting, detect data quality or operational issues, improve our services and operations, and support relationship management. We may also use information in permitted contract management, legal-intake and workflow records for internal contract administration and legal operations. This may include preparing summaries and status reports; identifying records that may need follow-up, such as potentially overdue approvals, stalled intakes, missing information or inconsistent workflow states; surfacing contract lifecycle dates and obligations; preparing counterparty or meeting briefings and draft internal updates; suggesting possible data quality issues; and analysing aggregated activity or workload to support prioritisation and resourcing. These tools provide decision support only. Their outputs may be incomplete or inaccurate and are checked by a person against the relevant source record before material reliance or sharing. They do not replace legal judgement, approvals or decisions by accountable process owners, or make solely automated decisions producing legal or similarly significant effects. (Lawful Basis: necessary for our legitimate interests in managing and improving our business operations, maintaining data quality, generating internal reporting and forecasting, managing business relationships, and improving our services, including internal contract administration and legal operations, maintaining accurate workflow records, and analysing aggregated contract and workflow activity for operational prioritisation, provided that those interests are not overridden by the interests or fundamental rights and freedoms of the data subject);
- manage and conduct our business and the services we provide to our Customers (Lawful Basis: performance of our contract with you and necessary for our legitimate interests in planning, managing and running our business operations efficiently and securely, including internal administration, reporting, supplier management and corporate governance);
- draft or assist with drafting business communications, account briefings, follow-up notes and similar materials using information held in those systems, subject to appropriate human review and, where relevant, compliance with applicable direct-marketing, consent, opt-out and suppression-list requirements (Lawful Basis: performance of our contract with you where relevant; otherwise our legitimate interests in managing our business relationships and communications; and, where required by law, your consent). We do not use these AI tools to make solely automated decisions that produce legal effects or similarly significant effects on you;
- make sure our website works properly, including debugging, to be able to deliver you its content, for DDOS mitigation on our website, and improving our website and performing statistical analyses (Lawful Basis: necessary for our legitimate interests in ensuring the security, integrity and availability of our Website and Merchant Dashboard, preventing abuse and cyber‑attacks, and understanding and improving how our services are used);
- effectively communicate with third parties (Lawful Basis: your consent, performance of our contract with you and necessary for our legitimate interests in managing our relationships and day‑to‑day interactions with Customers, suppliers, partners and other third parties in relation to the services we provide); and
- as required or authorised by applicable law (Lawful Basis: to comply with our legal obligations).
3.2. End-Users and Sub-Merchants
As explained above in the section “Individuals from whom we collect personal data (the ‘Data Subjects’)”, our relationship with End-Users and Sub-Merchants is mainly indirect. In most cases, we process their personal information to provide the Services to our Customers and in accordance with our Customers’ instructions. In that context, dLocal acts as a data processor on behalf of the relevant Customer under a written contract, relying on the Customer’s authorisation to process End-User and Sub-Merchant personal information.
In selected arrangements, Sub‑Merchants agree to the terms and conditions of our Customer’s platform, which incorporate the payment‑processing terms that govern how we provide our services and how we process End‑User and Sub‑Merchant personal data on behalf of the Customer. Acceptance of those terms is collected through the Customer’s own onboarding and consent flows (for example, via the platform’s online terms or API‑based consent capture), rather than through a separate, dLocal‑hosted interface. Therefore, if you are an End-User or Sub-Merchant who has a relationship with one of our Customers, you should also refer to their privacy notice, as it is likely to be relevant to you and would contain information on how to contact them if you have queries about their use of your personal information or if you wish to exercise your data protection rights.
Notwithstanding our general role as a data processor for our Customers, there are limited circumstances where we process End-User and Sub-Merchant personal information as an independent data controller. These circumstances include the purposes below:
- to conduct, as needed, fraud and other risk management and prevention, and to comply with any mandatory reporting related to such activities (Lawful Basis: to comply with our legal obligations or necessary for our legitimate interests in detecting, preventing and investigating fraud, financial crime, abuse of our services and violations of applicable network or scheme rules, and in protecting our Customers, End‑Users, Sub‑Merchants and our business from associated risks);
- to comply with our statutory, regulatory and/or professional obligations, including any record-keeping obligations which we may have at law (Lawful Basis: to comply with our legal obligations);
- to ensure the proper provision of the services for which you are either a recipient or beneficiary through our Customer and to exercise, or defend ourselves against, legal claims (Lawful Basis: necessary for our legitimate interests, including as to the reputation of our business or as pertaining to legal claims); and
- to carry out identity-verification and due-diligence checks for Sub-Merchants, which may include document verification where required by law or where necessary to prevent fraud and financial crime (Lawful Basis: to comply with our legal obligations (including KYC/AML, sanctions and other regulatory requirements that apply to us) and where necessary for our legitimate interests in verifying the identity and suitability of Sub‑Merchants, preventing fraud and financial crime, and protecting the integrity and security of our payment ecosystem).
In the context of those limited activities, we act as a data controller and therefore parts of this Privacy Notice would be relevant to you as an End-User or Sub-Merchant. Information on how to contact us for further information, or exercise your legal rights as a data subject, is set out at the end of this Privacy Notice.
Due to changes in the law or to our business, from time to time, we may need to, as a data controller, process your personal information for additional purposes beyond those set out above. In such case, we will either update this Privacy Notice or issue a dedicated privacy notice covering the specific occasion, depending on what is most appropriate to do in the circumstances.
4. WHEN WE MAY DISCLOSE THE PERSONAL INFORMATION
Your personal information may, for the purposes set out in this Privacy Notice, be disclosed for processing to:
- our employees, our affiliates and their employees. For instance, dLocal will share your information with other dLocal affiliates for the provision of our services or when such affiliates provide support services to dLocal;
- our third-party consultants, (sub-)contractors, suppliers or other service providers that may access your personal information when providing services to us (including, without limitation, IT support services; KYC and identity-verification providers; customer-support and messaging platforms; AI analytics and automation tools (including tools that use machine learning or large language models to analyse customer interactions and help us provide and improve our services); payment-method, tokenisation or credential-vault providers; acquirers, payment networks and payment-method providers; recurring payment and subscription billing service providers; and providers of sales intelligence, contact enrichment and lead generation tools);
- CRM, project management, contract management and other operational-tool providers; and providers of AI-enabled drafting, summarisation and analytics tools that process records, prompts, query metadata and generated outputs in connection with the services they provide to us;
- auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes;
- analytics and search engine providers that assist us in the improvement and optimisation of our Website and Merchant Dashboard;
- our successors in title, our prospective sellers or buyers of our business or to our Affiliates when we have a merger or re-organisation;
- government bodies and law enforcement agencies and in response to other legal and regulatory requests; and
- protect the rights, property, integrity or security of our company, our customers, or others (including, without limitation, you). This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where your personal information is provided to any other party in accordance with an express purpose, we will require such other party to ensure the safety and security of your personal information and only use it for the intended purpose.
5. INTERNATIONAL/CROSS BORDER TRANSFERS
dLocal serves customers globally. Accordingly, your personal information may be stored and/or transferred outside South Africa, including to countries where we have operations and where certain service providers are located. We transfer personal information in accordance with section 72 of the POPIA, including by ensuring the recipient is subject to a law, binding corporate rules or binding agreements that provide an adequate level of protection; by obtaining your consent where appropriate; or where the transfer is necessary for the performance of a contract with you or for your benefit. We use intragroup agreements and operator agreements imposing POPIAequivalent protections.
To protect your personal information when these are transferred and/or stored outside South Africa, we have implemented appropriate safeguards. You may contact us to request further information about the safeguards (subject to confidentiality).
6. WHAT HAPPENS IF YOU DON’T PROVIDE THE REQUESTED PERSONAL INFORMATION
If we are unable to collect personal information from or about you, or if the personal information provided is incomplete or inaccurate, dLocal may not be able to assist you, including providing the services you are seeking or provide support or assist you with your queries.
7. SECURITY OF PERSONAL INFORMATION
We have put in place a range of security procedures, as set out in this Privacy Notice. Where you have been allocated a profile in the Merchant Dashboard, this area is protected by your username and password, which you should never divulge to anyone else.
Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
We will use reasonable endeavours to implement appropriate policies, rules and technical measures to protect the personal information that we have under our control (having regard to the type and amount of that information) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
We will ensure that your information will not be disclosed to government institutions or authorities except if required by law (e.g. when requested by regulatory bodies or law enforcement organisations in accordance with applicable legislation).
We implement appropriate, reasonable technical and organisational measures to safeguard personal information in our possession or under our control, having regard to generally accepted information security practices and procedures, the nature of the information and the harm that could result.
If we have reasonable grounds to believe that the personal information of any data subject has been accessed or acquired by an unauthorised person, we will notify the Information Regulator and affected data subjects as soon as reasonably possible, describing the nature of the compromise, the information affected (where known), recommended measures to mitigate possible adverse effects, and our remedial actions.
8. COOKIES
dLocal uses cookies and similar technologies to store and collect information about your use of our Website and Merchant Dashboard. Cookies are small text files stored by the browser on your device. They send information stored on them back to our web server when you access our Website or Merchant Dashboard. We use certain cookies that are strictly necessary for the operation and security of our services, and we use other cookies (such as analytics or personalisation cookies) only where you have given your consent, as recorded through our cookie banner or preference centre. These cookies enable us, for example, to remember your settings and load your personal preferences to improve your experience. You can find out more about cookies at www.allaboutcookies.org, and more about the specific cookies we use and how to manage your choices in our Cookies Policy available on our Website HERE.
9. YOUR RIGHTS
We will take all reasonable steps to ensure that all information we collect, use, or disclose is accurate, complete and up to date. Please contact us if your details change or if you believe the information we have about you is not accurate or complete.
In some instances, you may also have the rights to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- Request erasure of your Personal Information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which you will be notified of.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You can also opt out of receiving direct marketing communications at any time by following the unsubscribe instructions in the relevant communication or by contacting us using the details set out in this Privacy Notice. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which do not override your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (i) if you want us to establish the information's accuracy; (ii) where our use of the information is unlawful but you do not want us to erase it; (iii) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) You have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out prior to the withdrawal of your consent or processing on other lawful grounds. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case.
How to exercise your rights.
Please click on this LINK and fill out the form to submit your request. This is the preferred channel to submit a request and exercise your rights. Requests submitted through other channels may require you to provide additional information to enable us to deal with the request. If we process your personal data as a data processor on behalf of one of our Customers (for example, where you are an End-User or Sub-Merchant), we may ask you to contact the relevant Customer directly or we may forward your request to them, where this is required or appropriate under Data Protection Legislation.
What we may require from you.
We may need to request specific information from you to help us confirm your identity before starting to work on your request. We may also contact you to ask for further information in relation to your request.
Time limit to respond.
We try to respond to all legitimate requests within one month from the date your identity is deemed to be confirmed. Occasionally, it may take us longer than that if your request is particularly complex, or you have made several requests. In this case, we will notify you and keep you updated.
No fee usually required.
All communication and all actions taken by dLocal regarding your rights described above are provided free of charge. dLocal reserves the right, in the case of clearly unfounded or unreasonable requests, to either take out a reasonable fee covering the administrative costs of providing the information or taking the requested action or refusing to fulfil the requested action.
10. HOW LONG WE KEEP PERSONAL INFORMATION
We will only retain your personal information for as long as you have agreed to it or when it is necessary for us to provide you with our services or fulfil the purposes we collected it for, in line with POPIA’s retention limitation and minimality principles, including to meet legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will take reasonable steps to destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by Data Protection Legislations. Where destruction is not technically or legally possible, we will minimise the information, logically segregate it and restrict access to it.
Where we use AI-enabled analytics, drafting or contract-management tools, we retain prompts, retrieved content, outputs, conversation history, logs and related governance records only for as long as necessary for the relevant business, security, audit, legal and compliance purposes. Retention of these materials may differ from retention of the underlying source records and depends on applicable provider terms and account settings. Where appropriate, we seek to retain and share aggregated or pseudonymised outputs rather than raw identifiable content.
11. Contact Details
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us by email at [email protected].
You have the right to make a complaint at any time to the applicable supervisory authority for data protection issues, which is the Information Regulator.
We would, however, appreciate the chance to deal with your concerns before you approach the Information Regulator so please contact us in the first instance.
12. CHANGES
We reserve the right to amend or edit this Privacy Notice from time to time to reflect changes in dLocal’s business or practices, and we encourage you to review this Privacy Notice periodically. We may change the Privacy Notice at any time by posting the changed Privacy Notice on the dLocal website. If the changes are material, we will include a notice on the dLocal website homepage indicating that a change has been made.