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PRIVACY POLICY
With Kirvano, your business is safe – and so is your data.
Please read this entire document carefully to be aware of the rules and workflows involving personal data.
Kirvano’s Economic Global Group is committed to your privacy.
The processing of personal data related to your use of the services provided by the platform is described in this document, which should always be interpreted in conjunction with our Terms and Conditions.
This Policy and its respective updates prevail over any prior proposals, contracts, understandings or agreements, whether verbal or written, that may have existed between you and any one of the Kirvano companies that you may interact with, especially concerning privacy or personal data. Moreover, by accessing and utilizing the services provided by Kirvano, you fully acknowledge and consent to the provisions outlined in this Policy.
1.OVERVIEW AND DEFINITIONS
This Privacy Policy applies to all services offered by Kirvano and intends to demonstrate, in a transparent and clear manner, what data we process, when it is collected, the reason for and how it is used, stored, processed, transferred, shared and consulted; in addition to defining when and how you can manage your privacy preferences.
For a better understanding of this Policy, find below the meanings of terms that, when started in capital letters, should be understood as follows:
“Kirvano” will always refer to all the legal entities that integrates the Economic Global Group, including Kirvano Pagamentos Ltda, based in Brazil, enrolled to the Brazillian Taxpayers Registry (CNPJ/ME) under the No. 48.582.146/0001-19, headquarters located at Barueri, state of São Paulo, on Rio Negro Avenue, 503, 23rd Floor, Suite 2301, Alphaville Empresarial, ZIP Code 06454-000; KVN Payment US Corp, based in the United States of America, headquartered at 800 North State Street, Suite 304, Dover, Delaware, 19901, registration EIN number 39-3925104; and Kirvano Services Solutions Limited, incorporated by the law of Nicosia, Cyprus, based at Promodrou Street, 75, OneWorld Parkview House, 4th floor, 2063.
“Data Controller” will be the legal entities of Kirvano, locally and globally, as the responsible for decisions and protocols regarding the collection, processing, storage, and deletion of data involved in operations.
“Platform” is the interface accessible through the domain kirvano.com or its subdomains, not including redirects to external domains or uniform resource locators operated by third parties non-integrants of Kirvano Economic Global Group.
“Services” refers to the available features and functionalities available at the Platform, aimed at processing payments and digital transactions globally.
“Personal Data” in the singular or plural, means any information that identifies an individual or that allows their identification, even partially.
“Data Subject User” is the individual who owns the personal data and who registers or uses the Kirvano platform. The User can be the buyer, the creator, or the affiliate, depending on how they use the platform's features.
“Sensitive Data” means information that reveals or is associated with intimate aspects of a person, which should have even more restricted circulation, such as racial or ethnic origin, religious belief, political opinion, membership in a union or religious, philosophical, or political organization, data relating to health or sexual life, genetic or biometric data when linked to a natural person.
“Data Processing” means any operation performed with personal data, such as collection, production, receipt, classification, use, access, copying, transmission, distribution, processing, archiving, storage, deletion, evaluation, control, modification, communication, transfer, dissemination or extraction.
2.COLLECTION OF PERSONAL DATA
We only request personal information when we truly need it to provide Services to you, and we do it by fair and lawful means, with your knowledge and consent.
When you register your profile as a Creator or Affiliate to have a logged-in account on the Platform, which provides access to dashboards and functionalities for managing products, offers, and receivables, we collect personal data such as name, email, phone number, ID number or tax identification, address, geolocation, device identifier, internet protocol, biometric data, and additional information that may be requested, if needed. We use the provided information solely to operationalize sales whose payments are mediated by Kirvano’s technology, reconcile available funds, and improve your asset management experience. We can also collect personal data directly from you, once you interact with us through any means, including by contacting our Support Team, Chatbot or Customer Services e-mails.
If you do not have a registered account, but access the individualized checkout to purchase a product through Kirvano’s gateway, in addition to information such as name, identification document, email, address, we can collect financial data, such as credit card number, transactional security code, and expiration date. We use this information exclusively for payments purposes and to process orders. If any complication arises during order processing, we will use this information to contact you.
The Data Subject User is solely and exclusively responsible for the accuracy of the Personal Data provided to Kirvano during registration or when using platform features.
We only have access to information as provided by the Data Subject User or that is available in publicly accessible databases. The verification and confirmation of Personal Data may be conducted by third-party companies, contracted by Kirvano contracted by Kirvano for this purpose, being these suppliers submitted to the same security and privacy criteria described herein.
The Data Subject User is free to refuse any requests for providing personal information, understanding that Kirvano may not be able to provide some of the Services for which access to the User's Personal Data is essential, or where non-identification makes the operation risky, inconsistent, illegal or prone to fraud.
3.DATA PROCESSING, INTERNAL USE AND SECURITY MEASURES
Kirvano, as a Data Controller, only processes and retains collected information to the extent necessary to provide you the requested Services. When we store data, we protect it within commercially acceptable and appropriate protocols and safety means to prevent losses, leaks or intrusions, as well as unauthorized access, disclosure, copying, use, or modification.
Kirvano may also conserve the personal data residually even after the circumstances of the end of processing of Personal Data, based on compliance of a legal or regulatory obligation, or even in circumstances in which there is a legitimate purpose, according to the legal allowances. In these cases, the Personal Data will undergo an anonymization process, will be stored in a secure place with restricted access and for the time necessary to comply with the obligation or purpose that it imposes.
Sensitive Data, as defined in applicable Data Protection Legislation, will not intentionally be requested or collected by default. In terms of Children Personal Data, we clarify that we do not request Personal Data of children under the age of 13, considering the minimum age limit for Users to access the Platform. In terms of financial data, such as credit card information, payment keys, and bank account identifiers, this will not be stored by Kirvano and will only be processed within the payment operational architecture, leaving no remaining legacy data.
4.LIMITED AND SPECIFIC THIRD-PARTIES SHARING
We only share your Personal Data information in such specific situations. If you use Kirvano as a payment and digital content platform, you acknowledge and agree that:
You give your consent for us to share your personal information with third parties when it is necessary to process and complete purchase orders, payment protocols, withdrawals, money transfers, content provision and access to the Platform main features and functionalities;
Kirvano is authorized by you to process, store and share your Personal Data, for the purpose of supporting procedures aimed at controlling and preventing fraud, in accordance with the guidelines established by the competent authorities;
We may be obliged to share your Personal Data with governmental, police authorities or with the judiciary, whenever necessary to comply with a judicial order or request from the respective identified authority.
Our Privacy Policy applies to domains operated by Kirvano, either directly or through contracted providers. The Platform and Kirvano’s website may have links to external domains that are not operated by us. Please, be aware that we have no control over the content and practices of external sites and, before providing any personal data to the referred pages, check the specific privacy guidelines linked to them.
5.YOU OWN YOUR PERSONAL DATA _ AND YOU CAN MANAGE IT
We preserve your rights regarding our processing of your Personal Data.
In case you want to ask us if we process your personal data, confirming the existence or otherwise of such processing; request access to a copy of your Personal Data processed by us; ask for information about which public or private entities we share your Personal Data with and what for; request the correction of your Personal Data that are incomplete, inaccurate or out of date, you can contact us through the e-mail privacy@kirvano.com. We will confirm receipt of your contact and will get back to you within a maximum of two business days.
If you want to deny or revoke your consent given to us previously, please contact us at the email address above to register your order, and your Personal Data will be deleted upon request, provided there is no legal or regulatory obligation that requires us to retain it for a specific period of time.
6.DATA PROTECTION OFFICER INFORMATION
If you have any questions about our Personal Data processing protocols, or want to file a complaint or register any requests related to this matter, please contact the named Data Protection Officer:
DPO:
Leticia Vieira Barbosa
Lawyer registered under brazilian law
Located at Jaceru Street, 225, Brooklin, São Paulo/SP, Brazil, ZIP CODE 04705-000
7.POLICY UPDATES
This Policy may be modified at any time, so it is important that you always review its terms.
When substantial alterations are made to these terms, you will be informed by e-mail or through Platform placed alerts.