Privacy Policy
CHAPTER I – GENERAL TERMS
OKADEV SOLUÇÕES TECNOLÓGICAS, a private legal entity registered under Brazilian company number (CNPJ) 23.343.176/0001-41, headquartered in the city of São Paulo, State of São Paulo, Brazil, at Avenida Conselheiro Carrão, 3502, room 12, postal code 03402-003, considers the relationship with its users and the treatment given to their information to be of the utmost importance. For that reason, through our Privacy Policy we set out our practices regarding the collection, use and disclosure of data that the user may provide through the Application and other associated websites.
What is personal data? It is information belonging to a person that allows them to be identified.
What is sensitive personal data? It is data provided by the user relating to ethnic or racial origin, religious belief, political opinion, membership of a union or of a religious, philosophical or political organization, data concerning health or sex life, and genetic or biometric data, as set out in Brazilian Law No. 13,709/18.
Authorization to collect and disclose. By using the platform, you authorize the collection, use and disclosure of your personal data under the terms of this privacy policy, and you agree to be bound by it. If you do not agree with these practices and policies, you will not be able to benefit from the features the platform provides or from any of the services we offer.
Regulation. Okadev Soluções Tecnológicas and the Kontro Platform operate in compliance with the legislation in force in Brazil, observing the terms of Law No. 13,709/18, the Brazilian General Data Protection Law (LGPD), and Law No. 12,965/2014, the Brazilian Internet Civil Framework, and will likewise follow the rules of any other laws that may apply and are relevant to the matters set out here.
Questions. If you have any questions about the Privacy Policy or the Terms of Use of the Kontro platform, you may contact the team at oi@kontro.com.br, or through the channels available inside the platform itself.
Control of personal data. This policy describes what personal data may be collected about you when you use the platform's services, how that personal data may be used, how you can control the way your personal data is used, and what precautions are taken against unauthorized access to or use of this personal data.
CHAPTER II – PERSONAL DATA COLLECTED
Collection of personal data. Kontro may collect and handle the following personal data of platform users:
A) If you are a customer: company name, individual name, phone number, tax registration number (CNPJ) and address — the last two being collected and handled only where the customer chooses to provide them.
B) Details of the transactions and operations you carry out within the platform;
C) Details relating to visits to the Kontro platform and to the features you use;
D) Server log information, which may include information such as the device's IP address, access dates and times, features of the Kontro platform or pages viewed, and other system activity, operating system, browser type and third-party sites or services used before interacting with our services;
E) Preference information about how you interact with our services, the preferences expressed and the settings chosen, which may involve the use of cookies, pixel tags and similar technologies to create and maintain unique identifiers;
F) Additional information such as individual preferences, language, postal code and area code, information about advertisements, and other information not limited to these.
CHAPTER III – HOW WE USE THE INFORMATION COLLECTED
3.1. Use
Kontro may use the personal data collected on the platform, described above, in order to:
A) Identify and register users on the platform, as well as make the services and all activities available;
B) Record users' searches and preferences on the platform;
C) Ensure that the platform's content is presented in the most efficient way for the user;
D) Help make general improvements to the platform;
E) Carry out internal operations, troubleshoot operational problems and software errors, run data analysis, testing and research, and monitor and analyze usage and activity trends;
F) Process the data collected through different internal or third-party algorithms of the service;
G) Contact and notify the user about changes to the platform, its deadlines, the services offered by Kontro, or its policies and terms of use, when necessary;
H) Analyze how users use the platform, for internal knowledge and marketing purposes;
I) Send newsletters and informational emails;
J) Where you are a visitor, offer Kontro's products and services through contact by email, phone or WhatsApp;
K) Provide user support and follow up on the platform experience to improve and optimize our products and services;
L) Contact users by phone, email or WhatsApp to follow up on usage and obtain feedback about the platform.
3.2. Additional data
Additional non-personal data — that is, data that cannot be used to identify you — may be used for any purpose regardless of authorization or notice.
3.3. Payment data
Personal data relating to payment is neither administered nor stored by the platform or by Kontro. This data is the sole responsibility of, and is used by, Stripe, Apple and Google, and the USER should review the privacy policies of those platforms.
3.4. Logs
Kontro keeps internet application access logs confidential, in a controlled and secure environment, using SSL-certified encryption, for a period of 6 (six) months, under the terms of article 15 of the Brazilian Internet Civil Framework.
3.5. Retention and deletion of personal data
Kontro guarantees the protection of personal data from the moment the user provides their data to Kontro, whether to purchase a product and/or service, to receive announcements, invitations and newsletters, or to improve and optimize their browsing experience on the platform. If the user requests the deletion of their personal data from the database, Kontro may retain some personal information for an additional period in order to comply with legal or regulatory obligations, to exercise its rights, and for auditing and compliance purposes. Personal data will be retained for as long as necessary to comply with the obligations described above, always observing the periods set out in applicable law.
CHAPTER IV – SHARING OF INFORMATION
4.1. Exceptions for disclosing users' personal data.
Kontro does not disclose to third parties any personal data provided by the user through the platform, except:
A) Where Kontro is required to disclose or share the data collected in order to comply with any legal obligation (such as a court order), or for the prevention of fraud or other crimes, as well as in response to a request for information from a competent authority, where we understand that disclosure is consistent with or required by applicable laws, regulations or legal proceedings;
B) To enforce any terms of use applicable to Kontro, or to enforce the terms of use relating to the services that may apply;
C) To safeguard the rights, property or safety of Kontro and of the platform;
D) Kontro may share personal data with suppliers, consultants, marketing partners, business intelligence and data analytics providers and other service providers who need access to the information in order to perform work on our behalf, all of whom are required to follow the same rules set out in this policy;
E) Kontro may share information with law enforcement agents, government authorities or third parties where we understand that their actions are inconsistent with the provisions of our terms of use, or in order to protect the rights, property or safety of Kontro or others;
F) If, upon prior notice, you agree to share it;
G) Through the user's own action;
H) In aggregated and/or anonymous form, ensuring that it cannot be used to identify you.
4.2. Non-disclosure of users' personal data
Except in the situations described above, KONTRO will not disclose any personal data of the USER, unless duly authorized by them or through the USER's own action, such as sending general personal data by email or posting on a social network, with the USER's authorization.
4.3. Additional personal data.
Additional personal data collected by Kontro through the analysis of each user's browsing, which does not make them personally identifiable (browsing patterns, for example), is the exclusive property of Kontro, which may use that information as it deems appropriate.
4.4. Right not to accept
The user has the right not to accept these policy terms and not to proceed with entering their data, or to request the removal of their data from the platform. However, removal has no retroactive effect, so actions taken prior to that removal will remain stored and used in accordance with Kontro's interests, subject to applicable law.
4.5. International transfer of personal data
In addition, some of the transfers described above may be made to recipients located outside Brazil. In that context, the companies undertake to do so only to countries that provide a level of personal data protection in line with best practices, always observing the legislation in force, and therefore granting users guarantees of protection of their data through specific contractual clauses, without prejudice to the prior collection of their specific consent where applicable.
CHAPTER V – COOKIES
5.1. What are cookies? Cookies are small text files that tell the browser about the user's activities, profile and behavior. This information does not contain any personally identifiable information.
5.2. Cookies used. Cookies can be used in different ways and forms. At Kontro, the following may be used:
A) Functional cookies: these cookies are used by the Kontro platform for some of its features, in order to offer a better browsing experience. For example, but not limited to, the cookie that records whether you selected the "Keep me signed in" option so that the site logs into the account instantly the next time you return to the page;
B) Performance cookies: this type of cookie collects anonymous information about how the USER uses Kontro so that we can optimize it. The information collected by these cookies never contains personal details from which you could be identified;
C) Advertising cookies: these cookies collect information about your browsing habits in order to make advertising more relevant to the USER, according to their interests. None of this information allows USERS to be unequivocally identified.
5.3. Access to cookies. Access to cookies ends as soon as the USER closes their browser. The USER is given the option to accept or refuse cookies. Most web browsers accept cookies automatically. However, if preferred, the USER may change the browser settings to refuse cookies.
5.4. Consent to the use of cookies. The Kontro platform is required to obtain your consent before using cookies. If you continue browsing the platform after accepting this Privacy Policy, we assume that you agree to the use of cookies under the terms described above.
5.5. Browsing without cookies. If you choose not to accept cookies, your access to most of the information available on the platform will not be compromised. However, you may not be able to fully use the online services offered.
CHAPTER VI – YOUR RIGHTS AS A DATA SUBJECT
6.1. Rights as a personal data subject. Kontro allows its users to exercise the rights provided for in the LGPD, and they may submit requests relating to their personal data, such as:
A) Access to personal data;
B) Anonymization, blocking or deletion of unnecessary or excessive data, or data allegedly processed in breach of the LGPD, except in the cases provided for by law;
C) Confirmation of the existence of processing;
D) Correction of incomplete, inaccurate or outdated data;
E) Deletion of data processed with the user's consent, except in the cases provided for by law;
F) Information relating to the processing, storage and destination of personal data under the LGPD;
G) Information about the possibility of not giving consent, and about the consequences of refusing;
H) Information about the entities with which their data has been shared;
I) Data portability to another service or product provider, upon the user's express request;
J) Withdrawal of consent.
6.2. Exercising these rights. Users may exercise the rights set out above by contacting the administrators at oi@kontro.com.br or through the other contact channels mentioned here.
6.3. Necessary protection measures. Kontro takes all necessary measures to safeguard users' personal data and to protect it against loss, misuse and unauthorized access, disclosure, alteration or destruction, using the latest technologies and SSL-certified encryption software, and adopting strict security standards to prevent unauthorized access to the data.
6.4. Password protection. The user is equally responsible for taking appropriate measures to protect their passwords, usernames and other special means of accessing their personal account on the platform.
CHAPTER VII – OTHER WEBSITES
7.1. Limit of liability. Kontro is not responsible for the privacy policies and practices of websites it does not operate, even where they are accessed through the platform. We recommend that users review the policy of each site they visit and contact the respective owner or operator if they have any questions.
7.1.1. Likewise, Kontro is not responsible for any information requested or policies arising from direct contact and agreements made between users.
CHAPTER VIII – NOTICE OF CHANGES TO THE PRIVACY POLICY
8.1. Changes to the Privacy Policy. Kontro may change the platform's Privacy Policy from time to time; therefore, the use of information collected at this moment is subject to the Privacy Policy in force. If Kontro makes changes to the way it uses its users' personal information, it will inform them through a notice on the platform or by email. In that case, the user becomes responsible for reading such legal notices regarding the changes.
8.2. Tacit acceptance. The user's continued use of the services after the effective date of any change made and previously notified automatically constitutes their acceptance of the amended or modified Privacy Policy. For this reason, Kontro suggests that platform users review this Privacy Policy whenever they use the Services.
8.3. Changes not notified. Minor adjustments to this Privacy Policy may occur without significantly affecting the way KONTRO treats the information collected, and such adjustments will not need to be communicated.
CHAPTER IX – USE OF EMAIL
9.1. Sending communications. By registering, the user allows Kontro to send to their email announcements, reports and news about the services or relevant information, as well as promotional material about new services from the platform and from its partners.
9.1.1. Opting out. The user may choose to stop receiving emails from Kontro, and may request this by sending a message to oi@kontro.com.br asking for their address to be removed from the mailing list.
9.1.2. Necessary messages. Registered users may not opt out of messages sent by the platform's administration that relate exclusively to the maintenance of their registration on the platform.
9.1.3. Anti-spam policy. Kontro always avoids sending users unsolicited or disruptive emails. It is therefore established that the use of the "Send this link to a friend" tool for spam purposes, or the indiscriminate sending of messages of any nature by email on the part of the platform, is strictly prohibited.
9.2. Confidentiality of email addresses. Kontro guarantees the utmost confidentiality in handling the list of user email addresses during regular administration tasks, in order to prevent misappropriation and misuse of that information, which is not disclosed online or to third parties.
9.2.1. Removal of email address. USERS are guaranteed the ability to remove the email addresses registered at the time of sign-up, using the permanently available services, in accordance with the legislation in force.
CHAPTER X – PROHIBITIONS
10.1. Removal. Kontro reserves the right to refuse or remove any connection that contains incorrect information or unsubstantiated claims, or that conflicts with the mission, policy and purpose of the company or of the platform.
CHAPTER XI – SECURITY OF PERSONAL INFORMATION
11.1. Users' personal account information is stored with the hosting provider, with SSL certificates, and only authorized platform staff may access personal information, being necessarily bound by confidentiality duties and strict respect for privacy.
11.2. If Kontro becomes aware of any breach of its own security or that of its hosting companies, including any hacking or other "break-in", we will notify you immediately of such breach and provide as much detail as we have regarding the nature and extent of the breach and the data compromised.
11.3. Permissions. Kontro, and anyone designated by it, may copy, disclose, distribute, incorporate and otherwise use the material and all data, images, sounds, text and other information incorporated into it for any and all purposes, whether commercial or not, provided the terms of this policy and the legislation in force are respected.
11.4. User liability. The user will be responsible for indemnifying KONTRO for all expenses and losses arising as a result of a breach of this policy or of the Terms of Use of this platform.
11.5. Cooperation. Kontro cooperates fully with any authorities or courts that request the disclosure of the identity or location of any person who has posted material on the platform in breach of the clauses set out in this policy.
11.6. Limitation of liability. This Privacy Policy addresses only the use and disclosure of personal data collected by the platform. If you disclose your personal data to third parties on open networks or through websites across the internet, different rules may apply to their use or disclosure of that information. KONTRO does not control the privacy policies of third parties to which you may be subject. We advise our users to review privacy policies before providing their personal data to third parties. KONTRO accepts no liability for any direct or indirect loss relating to the security of your personal data during its transfer over the internet.
CHAPTER XII – CONTACT
12.1. Contact. Users may contact Kontro at any time to share their views on privacy practices or on any matter relating to their personal information, by writing to oi@kontro.com.br or through the contact forms inside the platform.
This is a translation of Kontro's Privacy Policy, originally written in Portuguese. In the event of any conflict of interpretation, the Portuguese version available at kontro.com.br/politica-de-privacidade prevails.
