PRIVACY POLICY

We at KNEWIN INTELLIGENCE IN INFORMATION RECOVERY SA (“Knewin” or “We”), a business corporation, registered on CNPJ/ME under the nº 13.106.352/0001-78, are committed to safeguarding your privacy and protecting your personal data. The intent of this document is to clarify what information is collected through our website https://www.knewin.com/en/ , https://social.knewin.com/ and blog https://www.knewin.com/en/blog/ (collectively referred to as “Site”).

Knewin recognizes the importance of the right to privacy and, for that reason, uses its best efforts to protect it. This Privacy Policy details how Knewin collects, processes, uses, shares and stores personal data in the context of the Site, in compliance with applicable rules, in particular, the General Law for Protection of Personal Data, Law nº 13.709/2018 ( “LGPD”). 

This document was written with some examples of data collection and use, precisely so that you can read and understand, in a clear and accessible way, how we use your personal data to offer you a safe and comfortable experience in the use of services offered to you. 

This Policy is divided as follows:

1. Definitions
2. When this Policy applies
3. What are the sources of personal data
4. What types of data Knewin collects
5. With whom Knewin may share your Personal Data
6. International Transfer of Personal Data
7. What are your rights
8. For how much long your Personal Data will be stored
9. How Knewin protects your Personal Data
10. How to talk to Knewin
11. Changes in the Privacy Policy

1. Definitions

For the purposes of this Policy, the following definitions are adopted:

Personal Data or Data: is all information that makes it possible for a person to be identified or identifiable (“Personal Data”). Examples of personal data are: full name, identification documents, address, profession, email, telephone number, education level, among others;

Treatment(s): any operation carried out with a person’s Personal Data, with regard to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction of Personal Data;

Holder: is the natural person to whom the Personal Data that is the object of the Processing refers to.

2. When this Policy applies

This Policy applies to the Processing of Personal Data carried out by Knewin for the execution of the institutional website https://www.knewin.com/en/ , https://social.knewin.com/ and the corporate blog https://www.knewin.com/en/blog/. 

3. What are the sources of personal data

The amount and type of information collected by Knewin varies depending on your use of our services. We collect different data if you are visiting our website or using our software. 

This Policy applies to Personal Data We collect from or about you through the following sources: 

Knewin Sites: Consumer-facing sites operated by or for Knewin including sites that We operate under our own domains/URLs and mini sites that We maintain on third-party social networks such as Facebook, Instagram (websites). 

Ad Interactions: Interactions with our ads (when you interact with one or more of our ads on a third-party platform or website, we may receive information about that interaction). 

Data We Create: During our interactions with you, we may create Personal Data about you.

Events: Events hosted and organized by Knewin, as well as events in which Knewin participates as a sponsor, exhibitor or partner. 

User service: For the effective provision of the services offered by Knewin and considering their nature, we handle various Personal Data that are made available directly by our users for the provision of services. These Data are processed to meet the proper purposes in providing our services, as well as to comply with legal obligations. Examples of data collected in this context are: name, email, telephone number, home address, title, identification document numbers, bank details, among others. 

Marketing and sending communications: Knewin may use your Personal Data to send communications and marketing, aiming to target content according to your interests, as long as you subscribe to our newsletter. In this context, IP, name, email, telephone, among other data may be collected. 

Social Media: Knewin may collect Personal Data that was published and made available by you on social media, in accordance with the privacy settings set by you in each of the Social Media, as well as in accordance with the Privacy Policies of each source. In accordance with the transparency policy adopted by Knewin, we provide the links below to, if in your interest, change the privacy settings, minimizing or even preventing the collection of Personal Data on the social networks used by Knewin: 

● Facebook: Application Visibility and Privacy 

● Instagram: How do I disconnect my Instagram account from other social networks? 

● Twitter: About third-party apps and login sessions 

● YouTube: Third-party websites and apps with access to your account

● LinkedIn: Use of Data by Third-Party Applications

It is also worth mentioning that we store information about all contacts made with our users, regardless of the type of user who made the contact. Such information includes content/material downloaded from our pages and interactions by email, such as openings and clicks. 

By clicking on the content sharing buttons on social networks available on our pages, the user will be publishing the content through their profile on the selected network. Knewin does not have access to the login and password of users on these networks, nor will it publish content on behalf of the user without the user taking this action. 

It should be noticed that all the data we collect is used to provide our services. Therefore, all data and information about you are treated as confidential, and we will only use them for the purposes described and authorized by you, mainly so that you can use our services fully, always aiming to improve your experience as a user.

4. What types of data Knewin collects Site

Visitors:

If you access our Sites, we collect your browsing data. In this case, when you visit our website, a “cookie” is inserted in your browser through the Google Analytics software, to identify how many times you return to our address. 

“Cookies” are identifiers that we transfer to your browser or device that allow us to recognize your browser or device and inform us how and when pages and features on our services are visited and how many people access them. 

We also use Cookies and browsing data such as URLs (Uniform Resource Locators) to collect information about the date and time of your visit and the solutions and information for which you searched and viewed. Like most technology companies, we automatically collect this personal data and store it in log files whenever you visit our website or access your account on our network. We may use session cookies (which expire after you close your browser) and persistent cookies (which remain on your computer until you delete them) to provide a more personal and interactive experience on our website. Persistent Cookies can be removed by following the instructions in your internet browser’s help file. You can choose to limit, refuse or disable Cookies through your browser settings. However, by doing this, some areas of our website may not function correctly, which may prevent you from taking advantage of some of our features. 

Again, this Privacy Policy does not cover the use of Cookies by third parties, and we are not responsible for their privacy policies and practices. Please note that Cookies placed by third parties may eventually continue to monitor your online activities even after you have left our Services. 

Knewin Forms:

If you download one of our materials and/or content by filling out our forms or interacting with them, we collect, in addition to your browsing data mentioned in the Visitors section, your visit data to our pages, and other information you choose to share with us, through your interactions with our forms, Landing Pages and emails, for example.

In order to offer content and materials of interest to you, it is often necessary to cross-reference the data we collect from you, so that our marketing actions are directed towards what you expect to receive from us. We guarantee that this crossing is not done in a discriminatory way, not infringing any individual rights or freedoms. In addition, you can, at any time, request change or removal of such Data Processing permissions, by requesting contact us or e-mail dpo@knewin.com.

Considering all these points, some possibilities of using your data may occur. In this sense, we recommend that you read the examples below:

Your email is used for sending the material or information requested by you when filling out the form. It can also be used to send Marketing Newsletters, Customer Success, and also communicate the release of new free materials or new products from Knewin and partners. However, the user can unsubscribe at any time;

Knewin employees may occasionally contact you by email or telephone to do research or introduce products and services;

Send you messages regarding support or service, such as alerts, notifications, and updates;

Communicate with you about products, services, promotions, news, updates, events and other matters that you may be interested in; and

Carry out targeted advertising according to your tastes, interests and other collected information.

Users of Knewin Sites and Services

IIf you use any of our services and/or products, we will collect the following categories and types of personal data: contact data (name, email and telephone number), location data (country, state and city), professional profile data (position, name and segment of the company you work for, number of employees of that company, academic background and years of experience), billing data, data for marketing purposes.

For free trials, the following are collected:

1. contact data (name, e-mail and telephone)
2. professional profile data (position, company, company segment, number of employees in the

1. contact data (name, e-mail and telephone) 

2. professional profile data (position, company, company segment, number of employees in the company. 

3. For the contracting of our services and/or products, they are collected: 

4. data contact (name, e-mail and telephone), 

5. data professional profile (title, company, company segment, number of employees, CNPJ and interests); 

6. locational data (country, state and city); 

7. data billing and collection (corporate name or name, trade name, CNPJ or CPF, legal guardian and their CPF, head office address, credit card data, when opting for this method of payment, options regarding the Simples Nacional, data Supplementary Invoice issuance and payment currency for international customers)

It is important to emphasize that, during prospecting or projection meetings with clients, Knewin may make recordings via videoconferencing applications, such as Zoom Meeting and Google Meet, however such recording will only occur with the express consent of the client. 

The content of the recordings will be used exclusively within Knewin with the sole purpose of improving the prospecting techniques of the commercial team, being stored in Knewin’s database for a maximum period of 06 (six) months, when its elimination will occur.

5. With whom Knewin can share your Personal Data

Knewin can work together with other companies in a wide range of activities, including to provide location functionalities, marketing, advertisers, sponsors and business partners, online and offline, as well as dissemination tools and performance analyses. Therefore, we reserve the right to share your collected information with third parties, in Brazil or abroad, including location, registration and interest data, in order to properly fulfill the purposes listed in this policy, as well as to comply with order judicial decision or decision of any other competent authority, in accordance with the applicable law. Thus, Knewin may share or transfer Personal Data collected with third parties, inside or outside Brazil, in the following cases: 

• Partners: other companies we use to provide a service on our behalf and we need to share your Personal Data with them in order to provide our Services. For example, we use cloud/hosting services to store our database and share your Personal Data with technology providers. Our partners are only authorized to use Personal Data for the specific purposes for which they were contracted, therefore, they will not use your Personal Data for any other purpose, but to provide the contracted services.
• Analytics: Personal Data stored by Knewin may be used for analytics purposes, in order for Knewin to understand how users interact with the Site. These Personal Data do not identify or make identifiable individuals related to them and are used exclusively to better understand how the Site is used, in order to improve the products and services offered and improve the user experience.
• Advertising: Knewin uses digital marketing and advertising companies in order to send communications, target content and advertisements in a manner tailored to the interests of individuals who access the Site. To this end, some Personal Data may be shared between Knewin and these companies, particularly electronic identifiers, IP addresses,cookies and email, which can be used to measure the effectiveness of online advertising.
• For the protection and safeguarding of Knewin’s rights: Knewin reserves the right to access, read, preserve and disclose any Personal Data that believes to be necessary to comply with a legal obligation or a court order, without prior notice; enforce this Policy and other agreements; or protect the rights, property or safety of Knewin, its employees, users or others.

When we share your Personal Data with any of the organizations listed above, we limit the sharing to only the Personal Data necessary for the exercise of your functions and we contractually ensure that such Personal Data are used only to the extent necessary to provide the services on our behalf or for compliance with legal requirements. Likewise, we require that they commit to the same level of protection and privacy for your Personal Data that Knewin would have had if it had been handling it directly; this includes the obligation not to use your Personal Data for any purpose other than the contracted purpose, in addition

When we share your Personal Data with any of the organizations listed above, we limit the sharing to only the Personal Data necessary for the exercise of your functions and we contractually ensure that such Personal Data are used only to the extent necessary to provide the services on our behalf or for compliance with legal requirements. Likewise, we require that they commit to the same level of protection and privacy for your Personal Data that Knewin would have had if it had been handling it directly; this includes the obligation not to use your Personal Data for any purpose other than the contracted purpose, in addition to confidentiality obligations and information security standards, among others. Knewin does not rent, sell or transfer your Personal Data to anyone except the partner companies listed above.

6. International Transfer of Personal Data

The Data we collect may be transferred to the United States of America. This transfer is primarily for the purpose of cloud hosting Knewin’s partner servers.

By providing Personal Data to Knewin, the user agrees to the International Processing and transfer of such Personal Data to the United States of America. This Personal Data may be subject to local law and relevant rules.

7. What are your rights

You can always choose not to disclose your data to us, but for your knowledge some of this data may be necessary to register on our platforms or to use some of our features and products that we offer to you. Regardless, you will always have rights relating to the privacy and protection of your Personal Data, and we are not only concerned with the security of this data, we are also concerned that you have access to and knowledge of all your rights relating to Personal Data.

The General Law of Personal Data Protection guarantees rights related to privacy and the protection of Personal Data. We want everyone to have access to and knowledge of all rights relating to the Processing of their Personal Data.

Therefore, below we summarize certain rights that you have under the General Data Protection Law (LGPD), the other Brazilian sectorial laws relating to data protection and the General Data Protection Regulation (GDPR):

Right of access;
This right allows you to request and receive a copy of your Personal Data We hold about you.

Right of correction;
This right allows you at any time to request correction and/or rectification of your Personal Data, if you identify that some of them are incorrect. However, in order for this correction to take effect, we will have to check the validity of the data you provide us.

Right of exclusion;

This right allows you to ask us to delete your Personal Data from our platform. All data collected will be deleted from our servers when you so request or when they are no longer necessary or relevant for us to offer our services, unless there is any other reason for their maintenance, such as any legal obligation to retain data or need of preservation of these to safeguard Knewin’s rights.

Right to confirm the existence of Treatment; This right allows you, the data owner, to confirm that your personal data has been processed by a public or private company.

Right to request blocking or deletion; This right allows you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) when you need the data to be kept even if we no longer need it, as necessary, to establish, exercise or defend legal claims; or (c) if you object to the use of your data, but in this case we need to verify that we have a legitimate reason to use it.

Right to information from public or private entities; This right guarantees that you are informed by public or private entities that, by chance, will process your personal data.

Right to restrict processing; This right allows you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) when you need us to keep the data even if we no longer need it, as necessary, to establish, exercise or defend legal claims; or (c) you object to the use of your data, but we need to verify that we have a legitimate reason to use it.

Right to automated decision review;
You also have the right to request a review of decisions made solely on the basis of automated processing of your Personal Data that affect your interests.

Right to object to a Treatment;
When we are relying on a legitimate interest (or a third party) and there is something about your specific situation that makes you want to object to prosecution in that field, as you believe it impacts your fundamental rights and freedoms. You also have the right to dispute where we are processing your Personal Data for direct marketing purposes. In some cases, we can demonstrate that we have legitimate reasons to process your data, which override your rights, as in these cases it may be essential for the provision of the product and/or service.

Right to explain the logic behind collecting your data; You have the right to be informed about the criteria and processes used for the collection, processing and deletion of your personal data.

Right to information about the possibility of not providing consent and about the consequences of denial; You have the right to be informed about the possibility of not giving your consent to the processing of your personal data, as well as the consequences arising from this refusal

Right to withdraw your consent; You have the right to withdraw your consent, however this will not affect the legality of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products. And if that’s the case, we’ll let you know when that happens;

Right to request information regarding the sharing of Personal Data; You have the right to be clearly, appropriately and ostensibly informed about the shared use of your Personal Data, including the purpose of this sharing and the identification of the person with whom the sharing will be done; and

Anonymization, blocking or deletion of unnecessary, excessive or incorrectly treated Personal Data; You have the right to request anonymization (a data processing technique that removes or modifies information that makes it possible to identify the holder), block or delete Personal Data collected unnecessarily, excessively or processed in an improper way. incorrect.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise your other rights). This is a security measure to ensure that personal data are not disclosed to anyone who is not entitled to receive them. We may also contact you for more information regarding your request in order to expedite our response.

You can have any related questions or exercise these rights at any time using the form on the Knewin website: https://www.knewin.com/en/contact-us/ or e-mail dpo@knewin.com

8. How Long Your Personal Data will be Stored

Knewin will store Personal Data only for as long as is necessary to fulfill the purposes for which it collects it, including to comply with any legal obligations or request from competent authorities. Once the purpose of the Processing of Personal Data has been exhausted, it will be eliminated.

In order to determine the appropriate retention period for Personal Data, Knewin considers the quantity, nature and sensitivity of such data and the potential risk of damage arising from it. The unauthorized use or disclosure of your Personal Data, the purpose of the Processing and whether such purposes can be achieved by other ways, and the applicable legal requirements.

All Personal Data processed by Knewin will be deleted from our servers when requested by the Personal Data Subject or when these are no longer necessary or relevant for us to offer our Services, unless there is another reason for their maintenance, as a legal obligation to retention of data or need to preserve them to safeguard Knewin’s rights.

For more information on where and for how long your Personal Data will be stored by Knewin, as well as more information regarding your deletion and portability rights, contact: dpo@knewin.com 

9. How Knewin Protects Your Personal Data

The security, confidentiality and integrity of your information is important to us. Therefore, Knewin strives to protect the Personal Data it maintains in its records. Knewin adopts the best information security practices, of a procedural, administrative, technical and physical nature, which help us to prevent the misuse or unauthorized access, disclosure, alteratecurity procedures in order to improve them and always keep them up to date with current technologies and methods.

However, despite our efforts, it is not possible to guarantee that a transmission of Personal Data carried out by the Internet is completely secure. It is possible that third parties, not under our control, illegally intercept or gain access to transmissions or Personal Data. In addition to adopting all good security practices regarding your account and data, we ask for your cooperation to help us maintain a safe environment for everyone. If you identify or become aware of something that compromises the security of information, the user must get in touch through the form on the Knewin page: https://www.knewin.com/en/contact-us/ or e-mail dpo@knewin.com 

10. How to Talk to Knewin

If you believe that your Personal Data has been used in a way that is incompatible with this Privacy Policy or your choices, or if you still have questions or want to talk about anything related to this Policy, please contact us with us through the form on the Knewin website: https://www.knewin.com/en/contact-us/ or by email: dpo@knewin.com

11. Privacy Policy Changes

As Knewin is always seeking to improve its services, this Privacy Policy may be updated to include new technologies, industry practices, regulatory requirements, or to meet other purposes. Therefore, we recommend that you periodically visit this page to learn about possible updates. If material changes are made, we will post this update on the Sites, notify users by email to the last email address you provided us with, or by other means of communication in accordance with applicable law.