PRIVACY AND DATA USE POLICY

KGMG/TRADING CO.

Updated on 01/08/2.021.

 

This Privacy Policy sets forth how KGMG/Trading Co. ("we," "us," "our," or "us") collect and use personal information from customers and others (collectively, "you") who access or use our website, including www.kgmg.com. br ("our site", "our website", "this site", "the site", "the website"), mobile applications (if any), web client (if applicable) or professional client (if and when applicable), and/or any of our other websites (if any), products or services linked to this Privacy Policy (the "Services"), as well as other websites such as online wholesale, e-commerce in general, online retail and other websites that may be or become integrated into www.kgmg.com.br and under the same CNPJ of the company KGMG/Trading Co.

By using our Services, online, or directly on the website (if applicable) you understand that we will collect and use your personal information as described in this Privacy Policy.

If you or your company has an individual contract with us, that contract may contain privacy terms that also apply to the personal information you provide to us under that contract, if that contract covers activities and functions that pervade the Services on this website.

Please review the terms of that agreement, as those terms may be different or more restrictive than the terms of this Privacy Policy.

This Privacy Policy does not apply to third party applications and websites that you may use, including any application or website linked to our Services, especially those using API technology.

Please review the terms and policies of third party applications and websites before clicking on any links.

The Products and Services of KGMG/Trading Co. that make use of this website or online to be made and that make use of the website must follow the current regulations of the LGPD (General Law of Data Protection) in force in Brazil.

As part of our Services, users who register for newsletters or to join as members of use activities via this website, accept that we collect and record information that helps parties to prove the validity of mailing list/CRM (Customer Relationship Management systems) operations such as newsletter mailings, newsletters, activation of notifications on your computer (in case the user allows it) such as popups and other actions via emails, SMS, and other tools that are linked to the website directly and automatically (including information collected via this website's chatbot).

This information includes the people involved in the operations and the devices those people use.

We recommend that you read this Privacy Policy in its entirety to ensure that you are fully informed.

However, if you wish to access a section of this Privacy Policy, please refer to the topics: 1. Collection of Personal Data, 2. Use of Personal Data, 3. Sharing of Personal Data, 4. Preservation of Personal Information, 5. Privacy Rights, 6. Protection of Personal Information, 7. Changes to Privacy Policy and Use of Data, 8. Company Contact Information.

 

1. Collection of personal information/data

 

You may choose to visit our website, install our applications (if any) and/or provide us with personal information in chatbot, contact fill-in fields such as forms, and news and content shares. However, if you do not provide us with certain personal information, you may not be able to use some parts of our Services and our Online Service.

 

For example, if you do not provide a contact name, phone number, and email address on the chatbot, we will not be able to answer your questions or contact you to present the company's solutions and other information you have requested. If you are interested in obtaining our e-books or other information available on our website via downloadable .PDF files you will also be required to provide such data.

 

Regarding the personal information we collect, you provide us with personal information about yourself when:

 

Register for an account or access your account on our website;

Download a .PDF document;

Fill in the required fields to obtain personal information to send newsletters and request contact with our company;

Contact Customer Service via chatbot, email and online forms;

Make comments on our blogs or community forums.

 

You also provide us with personal information about other people when using parts of our Services, such as when:

Share information, such as news, pages, text, images and videos, and other content posted on the website;

Adds other users as members to an existing account (if applicable);

Leave comments in spaces provided for that purpose on our website;

Refer friends and third parties in forms, emails and chatbots, quoting personal information from them;

Your primary choice for this type of personal information is simply not to provide it, such as not creating a profile or leaving a comment on a blog.

Examples of the categories of personal information you provide:

Identifiers: name, email, job title/occupation, mailing address, social security number, phone and cell phone number.

Business information: your company information, such as company name, tax ID, location, phone numbers, emails.

Geolocation: physical location.

Personal Information We Collect Automatically

We automatically collect personal information from you and your devices when you use our Services, even when you visit our websites or applications without logging into your account, if any.

 

The categories of personal information we automatically collect include:

Device, Usage Information, and Operational Data. We collect personal information about how you use our Services and about the computers or other devices, such as cell phones or tablets, that you use to access our Services. Some examples include:

IP Address;

Precise geolocation information that you allow our applications to access (usually from your mobile device);

Unique device attributes and identifiers, such as operating system and browser type;

Usage data, such as: web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, home pages, pages and content viewed and the order of those pages, time spent on specific pages, the date and time you used our Services, the frequency of use of our Services, error logs, and other similar information;

Operational data, such as: names and emails of parties to a transaction, subject matter, history of actions that individuals perform on a transaction (e.g., review, subscribe, activate features), and personal information about those individuals or their respective devices, such as name, email, IP address, and authentication methods;

Cookies and Related Technologies. We may use cookies, which are text files containing small amounts of information that are downloaded onto your device ("Cookies"), or related technologies, such as web beacons, local object shares, and tracking pixels, to store or collect information. We also allow others to use Cookies on the Services, as described below. Cookies can store your preferences and username, and help personalize advertisements.

Analytics and/or tools that generate data for digital analytics. We use services such as Google Analytics, Google Tag Manager, Google Ads, Wix, and Ascend. These services may use Cookies to collect usage and navigation data and help us learn how people use our Services, such as the pages they visit and for how long, and the website or page they were on before accessing the KGMG/Trading Co. website.

 

Personalized Advertising.

Advertisements for other products and services.

Third parties whose products or services are marketed on our Services may place or read Cookies on your computer or other device to collect information. They do this to (i) tailor and serve advertising based on information such as prior visits to our Services and other sites, and (ii) generate reports about the number of ads served and responses to those ads.

 

Ads for our products and Services.

We may also use services, such as Google Ads, to serve customized advertisements about our products and Services to you on our Services and elsewhere. We allow these third parties to use and access their respective cookies on your computer or other devices that you use to access our Services. We do not have access to these cookies or related technologies, and this Privacy Policy does not govern the use of these cookies and related technologies on our website.

 

Information we collect from other sources.

We may collect personal information about you from others, such as:

 

Third Party Sources.

Examples of third party sources include marketers, partners, researchers, affiliates (such as companies connected with KGMG/Trading Co., if any), service providers and other persons when they have legal permission to share your personal information with us. For example, if you register for our Services from another website, the website may provide us with your personal information.

 

Other customers.

Other customers may give us their personal information. For example, if a customer wants you to access our website and perform a search on our pages, contact us or even purchase a service or product on our site, this customer may provide us with your e-mail and name in advance and/or you - when performing such actions on our website - will be subject to this Privacy Policy.

 

Combination of Personal Information from Different Sources.

We may combine personal information we receive from other sources with personal information we collect from you (or your device) and use it as described in this Privacy Policy.

 

Personal information we collect and process on behalf of customers.

When our customers use our Services, we process and store certain personal information on behalf of those customers as a data processor. For example, when you sign up for newsletters and promotions/contacts in general, this information is stored in our website database. This data may be used to update our mailing lists.

 

If you have any questions or concerns about how personal information is processed in such cases, including how to exercise your rights as a data subject, we recommend that you contact the customer or our call center.

 

We collect your personal information to provide and improve our Services and to support advertising and marketing.

 

We may share your personal information with third party service providers if they are authorized by us to provide us with services previously contracted by us and are duly registered in our systems with your knowledge.

 

2. Use of your personal information

 

In general, we collect, use, store and process your personal information to provide our Services, repair and improve them, develop new Services, and market our companies and their products and Services.

 

These are some examples of how we use the personal information we process:

Provide the Services and products requested by you and collect payments, when applicable;

Send you records of our relationship, including purchases or other events

Market features, products or special events using e-mail or telephone or send you marketing communications about third party products and services that we believe may be of interest to you

Record details about what happens to electronic documents, such as who views or signs them, the devices used, and when these events occur

Conduct sweepstakes, contests and refer-a-friend programs

Choose and deliver customized content and advertising, and support marketing and advertising for our Services

Create and review data about our users and how they use our Services Test changes to our Services and develop new features and products

Fix problems you may have with our Services, including responding to customer service inquiries and resolving disputes

Manage the Services platform, including support systems and security

Prevent, investigate, and respond to fraud, unauthorized access or use of our Services, violations of terms and policies, or other unlawful behavior

Comply with legal obligations

Comply with legal preservation periods

 

Other uses.

We may combine the personal information we collect ("aggregate") or remove portions of personal information ("de-identify") to limit or avoid identifying any user or device to help with purposes such as research and marketing. This Privacy Policy does not apply to our use of this aggregated or de-identified information.

 

Legal Rationale for Processing Your Personal Information.

 

If European data protection legislation applies and KGMG/Trading Co. acts as a controller, our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information at issue and the specific context in which we collect or use it.

 

Generally, we collect or use personal information from you or others when we have your consent to do so, when we need the personal information to perform a contract with you, or when the processing is in our legitimate interest and is not overridden by your data protection interests or fundamental rights and freedoms.

 

In some cases, we may have a legal obligation to collect or preserve personal information or we may need the personal information to protect your vital interests or the interests of another person. For example, when:

 

We use personal information to create and manage an account, this is necessary to provide the relevant Services.

 

We collect and record data associated with the use of a certificate or digital signature, this is to comply with regulations.

 

We use names and email addresses for email marketing purposes, we do so with your consent (which may be withdrawn at any time).

 

We collect usage data and analyze it to improve our Services, we do so based on our legitimate interest to protect and improve our Services.

 

If you have any questions or need further information regarding the legal basis on which we collect and use your personal information, please contact us using the contact information provided at the end of this Privacy Policy.

 

3. Sharing of Personal Information

 

We do not disclose your personal information to third parties in a manner that would be considered a sale under applicable law.

 

We share personal information as described below:

Service Providers.

We share your personal information with other companies that we use in support of our Services. These companies provide services such as intelligent search technology, intelligent analytics, advertising, authentication systems, account collection, fraud detection, and customer service. We have contracts with our service providers that address the protection and appropriate use of your personal information.

 

Affiliates.

We may share your personal information with other companies under common ownership or control with KGMG/Trading Co. These companies use your personal information as described in this Privacy Policy.

 

Marketing Partners.

We may share your personal information with sponsors of events, webinars or sweepstakes for which you register or other parties with whom we may engage in joint marketing activities.

 

Public or government authorities.

We may share your personal information to follow applicable law or respond to legal process (such as a subpoena). We may also share your personal information when there are threats to anyone's physical safety, violations of this Privacy Policy or other agreements, or to protect the legal rights of others, including our employees, users or the public. For more information, please see our Law Enforcement Guidelines and contact us as set forth at the end of this Privacy Policy.

 

Business Operations.

We may share your personal information during a corporate transaction such as a merger, sale of our assets or as part of the due diligence for these contemplated transactions. If a corporate transaction occurs, we will provide you with notice of any changes regarding the control of your personal information as well as the choices you may have.

 

Consent.

We may share your personal information in other ways, as requested by you or with your consent. For example, with your consent, we post user testimonials that may identify you.

 

Your personal information may also be shared as described below:

Other users.

When you permit other people to access, use or edit content in your account, that content is shared with those people. For example, if you send an email to others for review or subscription, the content is made available to them.

 

Third Parties.

When you make a payment to another user within our Services, we share the details of your payment method with the third party payment processor selected by you or the other user.

 

Public Information.

 

User-Generated Content.

When you comment on our blogs or in our community forums, this information may also be read, collected and used by others.

 

Profile Information.

When you create a profile on the KGMG/Trading Co. site, other KGMG/Trading Co. users may view your profile information that is public - if applicable - such as first and last name or email address. If you wish to make this information private, please visit your account settings and edit your data.

 

Your employer or company.

 

When you create an account or user role with an email address assigned to you as an employee, contractor, or member of a company,like seunome@seuempregador.com that company (if you are a client of KGMG/Trading Co.) may find your account and take certain actions that may affect your account.

 

4. Preservation of Personal Information

We do not keep your personal information longer than is necessary for the purposes for which it is processed. The period for which we retain personal information depends on the purposes for which it was collected and for which we use it and/or as required to comply with applicable law. If there are technical limitations that prevent deletion or anonymization, we protect personal information and limit its active use.

 

5. Privacy Rights  

This section describes many of the actions you can take to change or limit the collection or use of your personal information.

 

Profile.

You do not need to fill out a profile. If you do, you can access and review this personal information. If any of your personal information is inaccurate or incomplete, you can make changes to your account settings.

 

Marketing messages.

You may opt out of receiving marketing e-mail messages from us. You can opt out of receiving these messages by clicking on the "unsubscribe" link in the email message.

 

Please note that we may send you a message to confirm unsubscription. If you are a registered user of our Services or engaged in transactions with us, we may continue to send operational or relationship messages (for example: subscribe notifications or account notifications) after you have unsubscribed from marketing messages.

 

If you would like your phone number to be added to our internal telemarketing message opt-out list, please contact us at mkt@kgmg.com.br. Please include your first name, last name, company and phone number. You can also inform us during a telemarketing call that you do not wish to receive further calls for telemarketing purposes.

 

Cookies and other related technologies.

You may refuse cookies through your browser settings. However, if you decline cookies, you may not be able to use some parts of our Services.

 

To change how Google Analytics collects and uses your personal information, you can install the Google Analytics Opt-out browser add-on by clicking here (https://tools.google.com/dlpage/gaoptout).

To exercise your personalized advertising choices, please visit the following websites (please note that you may still receive advertising content, but it will not be personalized for you, and that KGMG/Trading Co. does not control these services that are offered by third parties):

 

Network Advertising Initiative consumer opt-out link (http://optout.networkadvertising.org/?c=1#!/)

 

Digital Advertising Alliance opt-out link (http://optout.aboutads.info/?c=2#!/)

TRUSTe Advertising Options (http://preferences-mgr.truste.com/) Google Ad Settings (https://adssettings.google.com/authenticated) For your mobile devices, please read the instructions for your operating system.

We may not recognize or respond to "Do Not Track" signals initiated by your browser. For more information about Cookies, Advertising and Options please visit our Cookie Notice.

 

Device and Usage Information.

If you do not want us to see the location of your device, you can turn off location sharing on your device, change your device's privacy settings, or refuse to share the location in your browser.

How to close your account.

 

If you wish to close your account, please log in and edit your plan. For more information, please send an email to: mkt@kgmg.com.br

 

Complaints.

We are committed to resolving valid complaints about your privacy and our collection or use of your personal information. For questions or complaints about our practices or our Privacy Policy, please contact us at mkt@kgmg.com.br.

 

Privacy of Minors

Our Services are not designed for and are not marketed to persons under 18 years of age ("minors").

 

We do not knowingly collect or solicit personal information from minors.

We do not knowingly allow minors to use our Services.

 

If you are a minor, please do not use our Services or submit your personal information to us. We delete personal information that we know is collected from minors without verified parental consent.

 

Please contact us at mkt@kgmg.com.br if you believe we may have personal information from or about a minor.

 

6. Privacy Rights - General Provisions on Data Protection and Personal Information

 

You may have certain rights related to your personal information, subject to local data protection law. These rights may include:

You may access and review personal information associated with your account at any time by accessing the My Account area on our website.

You may also request the following information: how we collect and use your personal information and why; the categories of personal information involved; the categories of recipients of your personal information; how we receive your personal information and its source; our business purpose for using your personal information; and how long we use or store your personal information or how we determine the relevant retention periods.

 

You have the right to correct your personal information.

 

In certain situations, you can request that we delete/delete or stop using, your personal information (and object to the use of your personal information) or export your personal information.

 

If our basis for processing your personal information is your consent, you have the right to refuse consent and/or, if provided, withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you may request that we stop using your personal information for direct marketing purposes.

 

You have the right to provide us with guidance on the use, storage and deletion of your personal information after your death.

 

You have the right to raise questions or complaints with your local data protection authority at any time.

 

You may have the right to receive information about financial incentives that we offer you. You also have the right not to be discriminated against (as provided by applicable law) for exercising some of your rights.

We will take reasonable steps to confirm your identity. If you have an account with us, we may confirm your identity by logging into your account. If you do not have an account with us, we may request confirmation by email or seek other identifying information, including government issued IDs, to confirm your identity.

You may authorize an agent to make a request on your behalf, and we will confirm the identity of your agent or authorized legal representative by requesting confirmation from you or through documents establishing the agent's authorization to act on your behalf.

Please note that your rights and choices vary depending on your location. Certain personal information may be exempt from these requests under applicable law. We need certain types of personal information in order to provide the product and Services to you. If you request that we delete this information, you may not be able to access or use our product and Services at a later time.

If you wish to exercise these rights, please contact us at mkt@kgmg.com.br

 

Transfers to other countries.

We may transfer your personal information outside of your jurisdiction for further processing, where applicable (such as e-commerce or direct Services of KGMG/Trading Co. transiting other countries and under the laws of those countries).

California, USA.

Residents of California, USA may request a list of third parties who received their personal information for direct marketing purposes during the past year.

This list also contains the types of personal information shared. We provide this list to you at no charge. If you are a resident of California, USA, and would like to request this information, please send an e-mail to mkt@kgmg.com.br).

 

How We Protect Your Personal Information

To keep your personal information secure, we use physical, electronic, and managerial tools. We apply these tools based on the sensitivity of the personal information we collect, use and store, and the current state of technology.

 

We protect your personal information by using technical and organizational security measures to minimize the risks associated with data loss, misuse, unauthorized access, and unauthorized disclosure and alteration.

 

7. Changes to Privacy Policy and Data Use

 

We may amend this Privacy Policy to reflect changes in legislation, our business, Services or data collection use and practices, or advances in technology. Our use of the personal information we collect is subject to the Privacy Policy in effect at the time this personal information is used.

Depending on the type of change, we may notify you of the change by posting it on this page or by email. Please review this Privacy Policy periodically and carefully review any changes made to this Privacy Policy.

 

8. Contacting

 

For questions or complaints about our use of your personal information or our Privacy Policy, please contact us at mkt@kgmg.com.br or by mail at:

 

KGMG/Trading Co., Subject: Privacy Policy, Rua Barao Geraldo de Resende, n. 97, Sala 801, 8. Andar, Botafogo, Campinas - Sao Paulo/SP, BRAZIL, CEP 13088-290.

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