4kst Data Protection Commitment

4KST Commitment
Personal Data Protection in Virtual Media

4KST is committed to fully respecting the right of every individual to their Privacy and the Protection of their Personal Data1. For this reason, we follow and comply with all national and international laws and regulations involving this topic wherever we do business, and we highlight the importance of the Brazilian LGPD law - General Personal Data Protection Law (Law 13.708/2018). In our "Personal Data Protection Policy" defines the standards adopted by 4KST, through its areas and employees, for the processing and protection of personal data.

This commitment documents the zeal assumed by 4KST in each and every operation it carries out with personal data collected or received in virtual format, whether they come from the company's most diverse relationships, such as data from:

• representatives of 4KST companies/clients;
• representatives of prospecting companies/clients;
• employees of the 4KST team;
• candidates for positions in the 4KST team;
• representatives of partner, supplier and investor companies; and
• consumers/individuals of 4KST companies/clients or prospecting companies/clients, etc.

4KST adopts the Principle of Necessity as the fundamental pillar of its work involving the processing of personal data. In other words, we limit our processing (from collection to storage) to the minimum necessary to conduct our activities, serve 4KST companies/clients and comply with legal requirements.

 

I'm an individual

Transparency is also one of our commitments to all those with whom we deal, and in this sense we try to clarify here any doubts you may have regarding how we treat and protect your personal data, including those you provide us when browsing the websites of our products and/or services. In addition to the information provided in this document, we also provide a communication channel so that you can talk to us and ask any other questions you may have about 4KST and your personal data (see the section "How can I contact 4KST?").

 

I'm a legal entity

If you represent a company that maintains or intends to start a new relationship with 4KST, whether as a customer, supplier or partner, this document can also be very enlightening about the way we handle personal data and our commitment to comply with the law. In any case, our
team is prepared to give you more details on the matter or, if you prefer, you can seek more information through our communication channel (see the section "How can I contact 4KST?").

 

Some of the questions you may have are answered in this document:

1. How and what data does 4KST collect about me?
2. Why does 4KST collect my data?
3. How and what data does 4KST receive about me?
4. Why can 4KST receive data about me?
5. How and with whom can 4KST share my data?
6. What precautions does 4KST take when processing personal data?
7. What are my rights as a data subject?
8. How can I contact 4KST?
9. How does 4KST serve public authorities?

 

1. How and what data does 4KST collect about me?

4KST collects personal data in the following situations:
4KST websites

• when you register your data to receive news, commercial campaigns, newsletters, or for our team to contact you;
• when you enter your details to purchase a 4KST product or service online;
• when you register your data to offer services or apply for a position in the 4KST team; and

Events

• when you provide your data in meetings with 4KST or events in which 4KST is a participant (e.g. webinars).

The collection of data in the above situations will always be preceded by an alert for you to give your consent and, in general, the data we will collect is as follows:

• name and/or surname
• e-mail
• the company it represents
• telephone
• city*
• professional information (profession, experience, education, etc)*

* This data is only collected when you access and register in the "Careers at 4KST" area, or on recruitment platforms provided by third parties and used by 4KST.

4KST System Authentication

If you interact with 4KST product systems (by logging in to use any of our products via the web) 4KST servers collect data to support any audit or investigation for improper use or access. The data that our servers may automatically collect is:

• information about your computer, cell phone, tablet or other device used for access; and
• authentication data such as:
  • login,
  • password,
  • Internet Protocol (IP) address,
  • type of browser,
  • language,
  • schedule,
  • language,
  • visited domain,
  • navigation information,
  • clickstreams (sequence of clicks made on our site) and
  • location

Cookie Usage Rules

4KST uses cookies on its websites to improve the performance and experience of its users.

Cookies are small files that a website, when visited by a user, places on their computer or mobile device via their browser. Placing cookies will help the website recognize the device the next time the user visits the same website.

The cookies used by 4KST do not collect information that identifies the user. Cookies collect generic information, specifically how users arrive at and use the 4KST website or the region from which the user accesses our site.

Cookies only retain information related to your preferences. At any time, you can choose to be notified of the receipt of cookies via your browser or block them from entering your system.

Refusing to use cookies on our website may result in you not being able to access some of its areas or receive personalized information.

Once you have authorized the use of cookies, you can always deactivate our cookies. All internet browsers allow you to accept, refuse or delete cookies by managing the settings in your browser. Please note that if you disable cookies, parts of our websites may not function properly.

 

2. Why does 4KST collect my data?

Personal data is collected by 4KST for the following purposes:

• offering their products or services;
• registration and participation in events;
• commercial negotiations;
• formalization of contracts;
• billing;
• processes for finding and selecting professionals to make up your team; and
• control of logins and authentications in 4KST systems and enable investigative processes for improper use or access.

 

3. How and what data does 4KST receive about me?

4KST provides services as a personal data operator for various segments, such as the financial market, manufacturing, insurance, retail, education, among others, serving various companies/clients through a formal relationship, and always on a legal basis.

Quite clearly, 4KST acts as a pass-through operator, receiving data controlled by the company/client, carrying out the processing contracted by the latter and fully disposing of all the data after each processing. In other situations, 4KST acts as a mere supplier of a technological platform for its clients to consult data bureaus.
bureaus.

You should be aware that 4KST does not own or maintain any personal data that is the subject of services provided to its companies/clients.

4KST always requires a formal commitment from its companies/clients to guarantee the legitimacy of the services they contract with us, either through the express consent of their clients or another legal basis for processing.

In general, the personal data that may be received by 4KST for the provision of services are:

• Name and/or surname;
• Date of birth and age;
• Gender;
• CPF;
• RG;
• Address;
• E-mail;
• Phone;
• Profession;
• Place of work; and
• Presumed income.

 

4. Why can 4KST receive data about me?

If 4KST receives data about you, you probably have or have had a relationship with a 4KST company/client that has contracted us to provide services to you. We build predictive models, which are tools used by our companies/clients for various purposes, such as credit analysis and anti-fraud.

 

5. How and with whom can 4KST share my data?

The personal data we collect virtually may be shared:

• With 4KST service providers that carry out credit card and other payment processing, marketing research and analysis, and customer support services;
• With offices contracted to carry out due diligence services (prior investigation), recruitment and selection of human resources;
• In special circumstances, with professionals who provide consulting, legal, structured operations, accounting, insurance services, or with third parties involved in mergers, corporate reorganizations, asset sales, among other operations in which 4KST is involved;
• 4KST investors; and
• With public authorities when it involves the fulfillment of legal and/or judicial obligations, or with professionals involved in conducting legal claims in which 4KST is a party.

The personal data we receive from our companies/customers may be shared:

• With data bureaus contracted by 4KST that perform data enrichment;
• With suppliers contracted by 4KST on an ad hoc basis to make a particular service possible;
• With public authorities when it involves the fulfillment of legal and/or judicial obligations, or with professionals involved in conducting legal claims in which 4KST is a party.

In all our contracts with suppliers or business partners, we require compliance with data protection regulations, as well as seeking confidentiality agreements that are consistent and aligned with our Personal Data Protection Policy and that especially limit the use or disclosure of this data.

We may share data about you that you have voluntarily made public, for example data published on social networks.

 

6. What precautions does 4KST take when processing personal data?

The entire 4KST team is trained and vigilant to only process personal data when it fully complies with current legislation on the matter. In addition, in each area of 4KST we have a designated Personal Data Protection Representative, who is responsible for supporting our Personal Data Protection Officer (DPO) in
identifying and monitoring risks involving non-compliance with the LGPD. The following are some of our internal rules that demonstrate this commitment:

• The personal data we process must be obtained fairly and lawfully, with the data subject's right to full information;
• Personal data must be collected exclusively for specified, explicit and legitimate purposes;
• Personal data must be adherent, relevant and not excessive in relation to the purposes for which it is collected and processed;
• Personal data will only be made available to third parties for the fulfillment of the specified purposes and when legally permitted;
• Personal data may not be retained for longer than is necessary to fulfill the purposes for which it was collected, except in cases where this data is required for legal reasons or where there is specific consent indicating a certain period; and
• When acting as a data pass operator, 4KST must delete personal data as soon as the service is completed and accepted by the data controller company/customer, with the exception of data that may need to be kept to comply with current legislation, for the purposes of audits and/or inspections.

4KST recognizes that it must fully protect all personal data under its custody, even temporarily. For this reason, it adopts control and auditing programs aimed at detecting, continuously monitoring and identifying possible violations of its internal rules that could lead to unauthorized access and/or disclosure of the personal data under its custody.

We use hardware and software from reputable suppliers. When data is transferred over the Internet, it is encrypted using Transfer Layer Security (TLS) or similar technology that provides encryption solutions. Encryption is a method of guaranteeing the confidentiality and authenticity of data during transmission and storage.

 

7. What are my rights as a data subject?

As the owner of your personal data, you should be aware of your rights under Brazilian law:

• Confirmation that your data is being processed;
• Access to your data;
• Correction of incomplete, inaccurate or outdated data;
• Anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of the LGPD;
• Portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;
• Revocation of consent;
• Deletion of personal data processed with the consent of the data subject, except in the cases provided for in the LGPD;
• Information on public and private entities with which 4KST has shared data; and
• Information about the possibility of not giving consent and the consequences of this refusal.

4KST has a procedure to guarantee agile and simplified service so that you can exercise any of your rights regarding your personal data that is under our tutelage, follow the guidance in (see section "How can I contact 4KST?").

 

8. How can I contact 4KST?

If you still have questions about how 4KST handles and cares for your personal data, or if you need to request any changes to the way your data is handled by 4KST, just contact our Data Protection Officer (DPO) by e-mail: dpo@4kst.com.

One detail: for your own safety and the protection of your personal data, when you contact us we will require some proof of your identity before we make any information available, or fulfill any request from you regarding your data. But rest assured, this whole process of confirming your identity will be done remotely/digitally.

In addition to this channel, please be aware that all our marketing materials contain a link so that you can electronically unsubscribe your data to stop receiving these materials.

 

9. How does 4KST serve public authorities?

4KST is committed to responding promptly to any Public Authority, in particular the ANPD, on issues related to the processing and protection of personal data carried out by it. Our DPO is available and can be contacted via e-mail: dpo@4kst.com, or via the address provided on our website https://www.4kst.ai.

 

¹ Personal data: any data that individually, or through a set of them, identifies or can identify a natural person.

4KST Commitment - Protection of Personal Data in Virtual Media - version 02
Published on 24/05/2021

dpo@4kst.com

compliance@4kst.com