PRIVACY POLICY

This Privacy Policy (Policy) is mandatory for the user who wishes to use the services offered by KINDICO DIGITAL MARKETING AGENCY LTD, registered in the company number 12236513, House, 24 Holborn Viaduct – London, EC1A 2BN United Kingdom, here in after called Kindico, we, us, through the site www.kindico.com (Site).

To use the Kindico SITE, it is essential that the user, hereinafter “You”, accept these Policy.

The Kindico Digital Agency (”We”) are committed to protecting and respecting your privacy.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.kindico.com you are accepting and consenting to the practices described in this policy

SCOPE

This statement applies to the following:

  • Personal information we collect through our website.
  • Personal information we collect about you in the course of doing business with you, such as when you engage with us a customer, potential customer, supplier, service provider, professional advisor, consultant or other third party in relation to the provision of our services and the operation of our business generally.

ABOUT THE PROTECTION OF YOUR PRIVACY AND PERSONAL DATA

Ensuring the protection of your privacy and your personal data is one of Kindico’s commitments (also called “we”, “us” or “our”). We adopt security, technical and administrative measures to protect your personal data from unauthorized access and accidental or illicit situations of destruction, loss, alteration, communication or any form of improper or illicit treatment. In addition, we require that those who may have access to your personal data have the same level of commitment.

In all personal data processing operations carried out in the digital and conventional media, this Privacy Policy (Policy) must be observed.

TERMS AND DEFINITIONS

For a correct understanding of the content of this Policy, it is considered:

  • Consent: a free, informed and unequivocal statement by which the holderagrees to the processing of his/her personal data for a specified purpose.
  • Anonymized data: user-related data that cannot be identified.
  • Personal data: information related to identified or identifiable natural person.
  • Elimination: deletion of data or datasets stored in the database, regardless of the procedure employed.
  • Fan place: Kindico’s trading partner; same as operator.
  • GDPR: General Data Protection Regulation EU 2016/679.
  • Operator: Natural or legal person, in public or private law, who carries out the processing of personal data on behalf of Kindico.
  • International data transfer: transfer of personal data to a foreign country or international organization of which the country is a member.
  • Processing: any operation performed with personal data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction.
  • User: the natural person to whom the personal data being processed refers; you; holder.

1. ABOUT PERSONAL DATA TO BE PROCESSED BY KINDICO

This Policy describes how the personal data of Kindico’s users will be treated.

Kindico will perform the processing of the following personal data related to the identified or identifiable user:

  1. name, e-mail address, gender, age, city, zip code, telephone number;
  2. cookies;
  3. images;
  4. IP address;
  5. traffic patterns.

The information collected may also be used to generate general statistical data for informational or commercial purposes, which may be provided to our operators anonymously.

2. ABOUT THE SPECIFIC PROPOSAL OF THE COLLECTION OF PERSONAL DATA

Your personal data will be collected by Kindico for the following purposes:

  1. send electronic communications with information related to services and products;
  2. so, you can use the site without repeatedly entering passwords or logins;
  3. to provide information or services that you have requested;
  4. to help us manage our content and ensure what is relevant and appropriate for you;
  5. to alert you to company news, product updates, updated information, and other new products and services.

We will not collect sensitive personal data relating to you, such as racial or ethnic origin, religious conviction, political opinion, union affiliation or Kindico affiliation, religious, philosophical or political character, health or sexual life data, genetic or biometric data.

2.1. About changes in purpose

If there are changes in the purpose of processing personal data that are not compatible with the original consent, you will be informed beforehand by Kindico about the changes of purpose, opportunity in which you can revoke your consent if you disagree with the changes.

2.1.1. About consequences of not providing consent

The user will be informed timely about the consequences of not agreeing to any changes in the purpose of the processing of personal data promoted by Kindico;

2.2. About the hypotheses of processing of personal data without the user’s consent

Without your consent, Kindico may collect your personal data only in the following hypotheses:

  1. for the fulfilment of a legal or regulatory obligation by Kindico;
  2. when necessary for the execution of a contract or preliminary proceedings related to a contract which the user is a party and to fulfil his/her request;
  3. for the protection of the life or physical incolumness of the user or third party;
  4. when necessary to meet the legitimate interests of Kindico or a third party, except in the event that the user’s fundamental rights and freedoms requiring the protection of personal data; or
  5. for credit protection, including the provisions of the relevant legislation.

3. ABOUT THE NEED AND ADEQUACY OF PERSONAL DATA

The data collected by Kindico will always be compatible with the purposes informed to the user. In addition, the treatment will be limited to the minimum necessary for achieving the intended purposes by Kindico.

4. ABOUT HOW PERSONAL DATA ARE COLLECTED

Please visit AboutCookies.org to find out how to delete cookies from your browser.

Your personal data are collected by Kindico in the following form:

  1. When we provide services to our clients, which includeadvertising and advertisement agency, including the forwarding agency by any means; planning, manufacturing, maintenance and updating of electronic pages; research and development services of any nature; recruitment, agency, selection and placement of labor;processing, storage or hosting of data, text, images, videos, electronic pages, applications and information systems, among other formats,and congeners; advertising agency, direct marketing and other services provided by Kindico.
  2. “Cookies”are small text files that are saved on your computer, which contain certain information that allows a website to recognize you if you visit it again. “Cookies”are used on www.kindico.com to save your country selection. This means that you will be directed to the appropriate page on your next visit.The “cookie” is only activated if you approve it being saved by clicking “OK”. “Cookies” are also used to recognize already registered users. You can delete “cookies” at any time using your browser settings.
  3. Every time a user accesses a page on the Kindico website and every time a file is accessed, access data about this action is collected and stored. The following data is stored: (i) the date/time of the request page from which the file was requested; (ii) name of the file accessed; (iii) amount of data transmitted, access status (file transmitted, file not found); (iv) a description of the operating system and web browser used, and (v) IP address and authenticated user name.
  4. Kindico’s website (www.kindico.com) uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, that is, text files saved on your computer which allow analysis of your use of the website, with the purpose of facilitating and customizing the user experience. “Cookies” by themselves do not reveal any personal information about the user in question, they only associate with the user’s IP. Most of the “cookies” used on our site will be deleted from the user’s hard drive automatically at the end of the browser session (called session “cookies”).Other types of “cookies” will remain on your computer andand they allow to identify the user’s computer on the next visit to our site (called permanent “cookies”). Our operators are not authorized to withdraw, use and process personal data obtained through “cookies” from our website. The information regarding your use of the website obtained through “cookies” (including your IP address) is sent to a Google server in the USA and stored there. Google uses this information to evaluate your use of the website; to generate reports on website activities for its operators and to provide additional services related to website and internet usage. Google will also share this information with third parties if requested by law or if third parties are contracted by Google to process this data. Under no circumstances will Google connect your IP address with other Google data. We would like to inform you that to increase data protection, our website uses Google Analytics with the extension “_anonymize()”. This means that IP addresses are abbreviated before they are collected and processed. This makes it impossible to connect the use of specific people to the analysis of the use of our website.
  5. In the act of registering or using any of our websites or applications.
  6. In the act of completing a form when attending a venue or event promoted by Kindico. The information may be provided directly by you, your employer or colleagues.
  7. Through the channels of record of criticism or doubt.
  8. Interactions with Kindico through social media sites or resources such as plug-ins or applications on Kindico sites integrated with social media sites.
  9. Automated technologies that may include the use of web server logs to collect IP addresses, “cookies” and web beacons.
  10. By accessing the Kindico websites on your mobile device, we may also collect the unique device identifier and mobile device IP address, as well as information about your device’s operating system, service provider,mobile phone and your location information.

5. ABOUT THE INFORMATION OF CHILDREN AND AOLESCENTS

Kindico’s websites do not perform operations to process the personal data of children and adolescents. Access to the Kindico websites is prohibited for minors under 18 (eighteen) years.

6. ABOUT THE DURATION OF PROCESSING OF PERSONAL DATA

Your personal data will be kept with Kindico for the period necessary to meet the purposes described in item1 of this Policy. However, even in the case of termination of the processing of personal data, Kindico may retain them in the hypotheses of: (i) compliance with legal or regulatory obligations; (ii) transfer to the third party, provided that the data processing requirements laid down in this Law are respected; or (iii) exclusive use of the data by Kindico, if they are not accessible by a third party and are anonymized.

If you have any questions, complaints and/or exercise of your rights, please contact Kindico by e-mail: info@kindico.com.

7. ABOUT CONTACT INFORMATION

Owner and Data Controller

  • Company Name: KINDICO DIGITAL MARKETING AGENCY LTD
  • Company Number: 12236513
  • Office Address: Woodberry House, 2 Woodberry Grove, Finchley, London, N12 0DR, UNITED KINGDOM

If you have any questions, complaints and/or exercise of your rights, please contact Kindico by e-mail: info@kindico.com

8. ABOUT THE EXERCISE OF RIGHTS BY THE USER

You have the right to obtain from Kindico, in relation to your personal data, at any time and upon request, the General Data Protection Regulation 2018 also gives you the following rights:

  1. confirmation of the existence of treatment;
  2. access to data;
  3. correction of incomplete inaccurate or outdated data;
  4. anonymization, blocking or deletion of unnecessary data, excessive or treated in disconformity with the provisions of this Law;
  5. portability of the data to another service provider or product, upon request expressed and observed the trade and industrial secrets, according to the regulation of the controlling organ;
  6. elimination of personal data processed with the consent of the holder, except in the hypotheses indicated in item 5;
  7. information of public and private entities with which Kindico has made shared use of data.
  8. to request the deletion or correction of information held about you;
  9. to complain to the relevant supervisory authority. In the UK this is the Information Commissioner’s Office (ICO) https://ico.org.uk/ whose contact details are as follows

You can exercise these rights by contacting us using the following contact details info@kindico.com, [Re: Privacy Compliance Officer]

For the exercise of his/her rights, the user will use the channel informed in item 6 of this Policy. The request will be answered without cost to the user.

9. ABOUT SHARING OF PERSONAL DATA

Kindico may share your personal data with operators who provide it with certain specialized services and are limited to the purpose for which your data has been provided. That is, Kindico will always share it in order to improving our services and to better respond to the needs of our users. Kindico may require operators to take the necessary administrative and technical measures to protect your personal data.

The user acknowledges that Kindico may store access records to other internet applications.

10. ABOUT COMPLIANCE WITH LEGAL REQUIREMENTS

Kindico may disclose your personal data in the following hypotheses: (i) is determined by the competent authorities; (ii) is necessary to investigate suspected or effective unlawful activity; (iii) the incorporation, merger or acquisition of Kindico occurs; (iv) to conduct audits; or (v) to investigate a security complaint or threat.

11. ABOUT THE SECURITY OF YOUR INFORMATIONS

Kindico follows the standards and best practices in information security to protect your personal data. Kindico has implemented reasonable physical, technical and administrative safety standards to protect personal information from loss, misuse, alteration or destruction. We protect your personal information from unauthorized access, use or disclosure using security technologies and procedures. Only authorized individuals access your personal information and they receive training about the importance of protecting personal information.

Our operators are contractually obliged to maintain the confidentiality of your personal data and may not use them for any unauthorized purpose.

We are committed to ensuring the protection of our users’ personal data and their privacy, through appropriate technical and administrative measures.

We have the SSL Certificate that is a digital security certificate to prevent third parties from accessing your data, it encrypts all of your information entered on the site during traffic between your machine and the site server. Hyper Text Transfer Protocol Secure is a security protocol that aims to inform visitors that the accessed site is secure for the exchange of information and it is protected.

The user is also responsible for adopting security measures, such as, but not limited to, using secured terminals protected by firewall, antivirus and anti-spyware; using updated browsers, properly configured, with valid digital certificates.

12. ABOUT KINDICO’S LIABILITY

It is Kindico’s liability to maintain records of the processing operations of personal data that it performs, especially when based on legitimate interest, with: (i) strict control over access to data through the definition of responsibilities of persons who will have the possibility of access and exclusive access privileges for certain users; (ii) prediction of authentication mechanisms for access to records, using, for example, dual authentication systems to ensure the individualization of the controller of the records; (iii) the creation of detailed inventory of accesses to connection records and access to applications, containing the moment, duration, identity of the employee or the person responsible for the access designated by the company and the file accessed; and (iv) the use of records management solutions through techniques that ensure the inviolability of data, such as encryption or equivalent protection measures.

In the case of operators who perform the processing according to the instructions provided by Kindico, it will be under the responsibility of Kindico to verify compliance with its own instructions and the relevant standards.

Kindico does not exercise any control over the content of its website(s), precisely to ensure freedom of expression and prevent censorship. However, the content indicated as infraction generated by a third party will only become unavailable by Kindico after receipt of a specific judicial order that determines the said providence. This rule is also applicable to the use of the software or download content and/or damage caused by malicious code.

We remind you that the exemption from our liability is also applicable to hyperlinks related to the content of third parties, since we cannot control, modify and therefore are not responsible for their content. In this way, we suggest the user to read carefully the information about the privacy and protection of personal data on all websites accessed.

13. ABOUT AUTOMATED DECISIONS

If Kindico defines the user’s personal profile and/or personality aspects in an automated manner, you will have the right to request a review of decisions taken solely based on automated processing of personal data affecting your interests.

14. ABOUT THE INTERNATIONAL TRANSFER OF PERSONAL DATA

The international transfer of your personal data may be carried out by Kindico, without prejudice to other hypotheses provided in law: (i) for countries or international organizations that provide a degree of protection of personal data appropriate to that provided in the GDPR; or (ii) when Kindico establishes contractual clauses that demonstrate the offer and proof compliance with the principles, user’s rights and data protection regime provided in the GDPR.

15. ABOUT THE LEGAL BASIS

In any personal data processing operation in which at least one of the acts occurs in the national territory, the UK legislation and the rights to privacy, protection of personal data and confidentiality of private communications and records must be respected.

In any personal data processing operation in which at least one of the acts occurs in the national territory, the Brazilian legislation and the rights to privacy, protection of personal data and confidentiality of private communications and records must be respected.

This Policy is in harmony with the regulations:Law 2016/679 General Data Protection Regulation EU (GDPR) and Law No. 12.965, of April 23rd, 2014 (Civil Marco ofthe Internet) and Law No. 13.709, of August 14th, 2018 (General Law on Personal Data Protection BR).

16. ABOUT AMENDMENTS TO THIS POLICY

This Policy will be reviewed and updated annually or when legislative changes occur. The new version of the Policy will be published on Kindico’s website and the version date will be located at the bottom of this page.

It is important that you periodically read this Policy so that you are aware of our privacy practices.

The Data Controller is not responsible for updating all the links displayed in this Policy, therefore, whenever a link is not functioning or updated, Users acknowledge and agree that they will always have to refer to the document or section of websites referred to by such link.

This Policy was last updated on October3, 2019.