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PRIVACY POLICY

KLAVE

A Personal Data Privacy Policy da KLAVE was created to demonstrate the company's commitment to the security and privacy of information collected from users, in addition to establishing clear rules regarding the processing of your personal data through the services provided through our website, that is, we intend to detail here what data we collect, why we collect it, and how you can update, manage, export or delete this information.

The protection of user data is a priority for KLAVE. For this reason, we recommend careful reading of this document to understand how we handle your information and what your rights are.

This Privacy Policy applies to all services offered by KLAVE through its platform, including its functionalities, and any interaction between the user and the company.

User information will not be provided, published or commercialized under any circumstances, except as provided in this Privacy Policy.

We recommend that users check this policy regularly, as it is subject to changes without prior notice. However, any significant changes will be communicated through our website, where the previous policy was available. If the changes impact the previously provided consent, KLAVE will request new express authorization from the user before proceeding with the processing of personal data under the new terms.

1. PROCESSING AGENT

When using the KLAVEplatform, you provide us with your personal data so that we can offer our services and ensure a quality experience. For KLAVE, security and reliability are fundamental principles, therefore, we constantly apply the best security practices, implementing appropriate technical and organizational measures to protect your data against unauthorized access, destruction, alteration or disclosure, ensuring its reliability and integrity.

The Controller of your data, that is, the person responsible for deciding what will be done with them, will be KLAVE TECNOLOGIA E BLOCKCHAIN LTDA., a private legal entity, registered under CNPJ/MF No. 42.355.765/0001-94, with address at Rua Anita Garibaldi, No. 600, Upper Floor, Centro, Itajaí/SC, ZIP 88.303-020, hereinafter referred to as KLAVE.

A KLAVE collects and processes data from its customers, potential customers, and any individuals who contact it, respecting the limits, purposes, and intentions set forth in this document.

1. INITIAL OBSERVATIONS

Fan Communication. The platform allows artists and companies to use communication tools, such as sending emails, WhatsApp, and SMS, to communicate with their fans. KLAVE has no control over the content of these communications and is not responsible for the misuse of information collected by platform users.

Monetization. The platform offers monetization tools that allow users to sell products to their fans. Personal data used for these transactions is protected as described in this policy.

Access Control. Each user will have access only to their own fans' data, ensuring that an artist or company does not have access to another's fan base. This separation is technically implemented on the platform and must be respected by users.

User Responsibility. Platform users are responsible for processing the data they collect through KLAVE. This includes compliance with legal and regulatory obligations related to data protection, as established by the LGPD (General Data Protection Law). KLAVE is not responsible for actions taken by users with the collected data, including, but not limited to, misuse or fraudulent use.

Payment Plan and Subscription. KLAVE uses Stripe as a monthly recurring payment method, similar to services like Spotify and Netflix. Payment information is securely managed and does not occupy users' credit card limits. Additionally, KLAVE.

2. ABOUT THE DATA WE COLLECT

Personal data is considered to be data that directly identifies a person, such as their name, as well as data that, although not immediately identifying someone, can be used for such purposes, such as your device's serial number. We also collect anonymized data, which, in turn, is not considered personal data by the LGPD, as it does not allow the identification of the data subject, provided that the anonymization process cannot be reversed. On the other hand, we do not collect sensitive data, such as information about health, sexual orientation, or religion, unless specifically requested with the user's explicit consent.

We collect your data when you voluntarily submit it, for example, when filling out your registration on KLAVE's website. Additionally, your browsing data may be collected, for example, when you click on a site feature that directs you to a partner's page. As for usage data, it is automatically collected while you use the site.

We also collect data originating from the use of our services, that is, new information that is generated from the data initially provided by you, which after interaction with our services, generates new data.

2.1 We collect your personal data whenever you:

  • Register through KLAVE's website or its landing pages;
  • Log in to KLAVE's website;
  • Request to contract any of our services/products;
  • Contract or use any of our services;
  • Subscribe to KLAVE's newsletter;
  • Request support or additional information through our support channels;
  • Participate in surveys conducted by KLAVE;
  • Complete a purchase checkout.

2.2 In addition to your data, we will have personal data from whom:

  • Are or were our client;
  • Made some transaction with us or with any of our clients;
  • Is or was a representative, attorney, guardian, curator, employee or partner of a client, some company or entity with which we have a relationship.

2.3 This Privacy Policy also applies to other forms of personal data collection carried out by KLAVE, which enable the offering or improvement of our services. For example, we can obtain information through partners or our technologies. All collection modalities and purposes for which we use your personal data are detailed in this Privacy Policy.

2.4 We do not intentionally collect personal data from minors under 18 (eighteen) years of age without the consent of their legal guardians. If you are under age, you may only use our site or provide your personal information with proper authorization from your guardian. If we discover that we have collected data from a minor without this authorization, we will take the necessary measures to exclude this information from our records.

2.5 The practices described in this Privacy Policy refer exclusively to the processing of your personal data in Brazil and are in compliance with local laws in force, especially Law No. 13,709/2018 (General Data Protection Law, or "LGPD"), according to its most current version, including future modifications.

3. WHAT DATA WE COLLECT

When KLAVE collects your data, they are processed according to the purposes provided by Law.

We emphasize that, at any stage of data processing, we may use artificial intelligence tools to improve our services, always in compliance with current legislation.

3.1 Data Provided By The Holder

  • Full Name;
  • Nationality;
  • Identification documents, such as RG, CNH, among others;
  • E-mail;
  • Phone Number;
  • Address;
  • Date of Birth;
  • Filiation;
  • Gender;
  • Profession;
  • Declared income;
  • Geolocation.

3.2 Why We Collect This Data

  • Provision of services and offering of contracted products;
  • Execution of preliminary procedures related to the contract to which the holder is a party;
  • Identification, authentication and verification of requirements for contracting services and products of
  • Handling requests and questions;
  • Contact by phone, email, SMS, WhatsApp, or other means of communication, including for sending notifications or push, for marketing purposes and other related dealings, products and services;
  • Offer CRM services, according to your interest and interaction with the available content;
  • Marketing activities, prospecting, market and opinion research, as well as the promotion of products and services of
  • or those of our partners or clients, including enabling offers and sending information about products, services, news, features, content, news and other relevant events to maintain our relationship with you;
  • Improvement of provided services;
  • Prevention and resolution of technical or security problems;
  • Regular exercise of the rights of
  • or our clients, including, when necessary, the presentation of documents in judicial and administrative proceedings; including for contract compliance;
  • Cooperation or compliance with court orders from competent authorities or supervisory bodies.

3.3 Navigation and Device Data

  • Approximate location;
  • Device attributes, such as ID, operating system, browser, model and related information;
  • Cookies;
  • Navigation and device data;
  • Platform performance data;
  • IP address of the mobile device used to access our site;
  • Social network account authentication data, if login is made through third-party platforms (for example, Spotify, Apple Music, Deezer and Youtube);
  • Technical data, such as URL information, network connection, provider, and device information.

3.4 Why We Collect This Data

  • Provision of services requested by our customers;
  • Execution of preliminary procedures related to the contract to which the holder is a party;
  • Advertisement personalization;
  • Improvement of browsing experience;
  • Operationalization of new products and services;
  • Recommendation of new services, products or site features, including partner services that may interest you;
  • Generation of statistics, studies, research and surveys relevant to activities and behavior in the use of products or services;
  • Prevention and resolution of technical or security problems;
  • Compliance with court orders from competent authorities or supervisory bodies.

3.5 Publicly Available Data

We may collect information about you that is publicly accessible or that you have made publicly available.

3.6 Why We Collect This Data

Check items 3.4 and 3.2.

3.7 Sensitive Data

Your sensitive data, when collected, can be processed by KLAVE according to the legal bases provided in Article 11 of the LGPD, including: Specific and prominent consent from the holder or their legal representative, for the following purposes:

  • Compliance with legal or regulatory obligation;
  • Regular exercise of rights in judicial, administrative or arbitration proceedings;
  • Protection of the life or physical safety of the holder or third parties;
  • Guarantee of the holder's data security, including processes of identification and authentication in electronic systems.

4. DATA SHARING

The purposes described in this document may justify the sharing of data under the controller's control with partner platforms, other entities and affiliates controlled by KLAVE, always in accordance with the controller's instructions. We may also share your data with service providers, authorities and regulatory bodies, as well as cloud hosting providers and/or external servers, located in Brazil or abroad, when necessary and authorized by the data controller

Additionally, your data may be shared with other third parties, always within the limits established by current legislation and according to the controller's guidelines. Finally, your data may also be shared upon your request, respecting legal limits and requirements.

4.1 Partner Platforms, business partners and other third parties

  • Improvement of our services, website and operationalization of new products or services;
  • Assistance in providing the services we deliver to you;
  • Contact by phone, email, SMS, WhatsApp, push notification or other means of communication;
  • Checking your identity and eligibility to contract our services;
  • Marketing, prospecting, market research, opinion surveys and promotion of our products and services;
  • Prevention and resolution of technical or security problems;
  • Regular exercise of rights;
  • Compliance with court orders from competent authorities or supervisory bodies;
  • Compliance with legal or regulatory obligations.

4.2 Business Transfers (other entities and affiliates controlled by KLAVE)

  • Meet the commercial and operational needs of the business group;
  • Execution of commercial operations, such as the sale or acquisition of assets. If another company buys KLAVE or its assets, it may assume the rights and obligations related to your personal information, provided there is express user consent;
  • In case of bankruptcy or judicial reorganization, personal information may be considered company assets and, therefore, may be sold or transferred to third parties as part of the process, always with the express consent of the user.

4.3 Authorities and Regulatory Bodies

  • Regular exercise of KLAVE's rights, including the presentation of documents in judicial and administrative proceedings, when necessary;
  • Compliance with court orders and requests from competent authorities or supervisory bodies;
  • Compliance with legal or regulatory obligations.

4.4 Upon your request

  • Ensure transparency in our relationship with you;
  • Send non-mandatory notifications via email, push, WhatsApp and SMS.

Additionally, when redirected to third-party websites or applications, your personal data may be shared with these entities, according to their respective privacy policies and for the purposes provided by them.

5. INTERNATIONAL TRANSFERS

Some of your personal data may be transferred to other countries, for example, when we use cloud computing services for data processing or storage. It is worth noting that all requirements established in current legislation are observed, adopting the best market practices in order to guarantee the protection and privacy of your personal data.

By accepting this privacy policy, the user explicitly consents to this data transfer.

6. DEVICE PERMISSIONS FOR ACCESS TO PERSONAL DATA

To ensure the proper functioning of certain platform features, it may be necessary to request specific device permissions. Among the permissions that may be requested are:

  • Contact permission: To access the device's contact list;
  • Camera permission: To allow the application to take photos or record videos;
  • Microphone permission: For audio recording or voice commands;
  • Social media account permission: To facilitate login via social networks or content sharing;
  • Approximate location permission (continuous): To provide services based on user location.

7. RIGHT TO NOT PROVIDE PERSONAL DATA

KLAVE follows strict security and confidentiality standards to protect your personal information. All personal information provided will be collected through ethical and legal means, so users will be informed about the purpose of collecting information and, therefore, it will be up to them to choose whether or not to provide the information. KLAVE will maintain the integrity of personal information provided by users.

You are not required to provide the personal data we request. However, if you choose not to provide it, in various situations, we may not be able to offer our products or services, nor meet your requests.

8. YOUR RIGHTS AS A DATA SUBJECT

You are the holder of all rights provided in art. 18 of Law 13,709 of 2018. This means that, at any time, you can exercise any right exposed there and as exemplified below in this term. These rights may be exercised before consumer protection organizations, as well as the National Data Protection Authority (ANPD).

  • Confirmation of personal data processing

    You can request KLAVE to confirm if it processes your personal data.

  • Access to personal data

    You can request KLAVE to provide the personal data it has about you.

  • Consent revocation

    You can revoke the consent given to KLAVE for the processing of personal data. This revocation may result in the termination of services provided, but does not prevent the use of anonymized data, and data whose processing is provided for in another legal hypothesis provided for in the LGPD.

  • Correction of incomplete, inaccurate or outdated personal data

    You can request the correction or complementation of your data to KLAVE, upon proof of the current and correct data.

  • Elimination of personal data

    If any personal data is processed unnecessarily, excessively or in disagreement with the LGPD, you may request KLAVE to anonymize, block or eliminate this data.

  • Information about sharing

    You can request KLAVE to inform with which third parties it shared your personal data or from whom it received your data.

  • Information about consent

    You have the right to choose not to provide your personal data, and must be informed about the consequences of this refusal, such as the possibility of not receiving news from your favorite artist.

  • Portability and right of petition

    When the right to portability is regulated by the National Data Protection Authority (ANPD), you may request KLAVE to port your personal data to another service provider. In addition, you have the right to submit petitions to ANPD regarding the processing of your personal data.

If you wish to exercise any of these rights, contact us through our SUPPORT CENTER at [email protected]. The request will be processed within 15 (fifteen) business days, except in exceptional situations that may justify a longer period. To exercise these rights, we may request proof of your identity as a security measure and fraud prevention.

All requests will be handled free of charge and will be subject to a prior assessment of your identity and the feasibility of compliance, in order to comply with any obligations that prevent full compliance with the requests of rights holders.

9. LEGAL BASIS

For better clarity regarding the use of data, we seek to outline the processing of data in accordance with the legal basis provided for in Law 13,709/2018, aiming to provide maximum possible transparency.

9.1 According to the provisions in Article 7 of the LGPD, within the following legal hypotheses:

  • Consent of the data subject;
  • Legitimate interest of KLAVE, its clients or third parties;
  • Regular exercise of rights, including in judicial, administrative or arbitration proceedings;
  • Protection of life or physical safety of the data subject or third party;
  • Compliance with legal or regulatory obligation.

9.2 As for your sensitive data, if collected, they will be processed in accordance with Article 11 of the LGPD:

  • Specific and prominent consent from the data subject or their legal guardian;
  • Compliance with legal or regulatory obligation;
  • Regular exercise of rights, including in judicial, administrative or arbitration proceedings;
  • Protection of life or physical safety of the data subject or third party;
  • Guarantee of fraud prevention and security of the data subject, in identification and authentication processes for registration in electronic systems.

10. ACTIVITY LOG

We may record the activities performed by you when using our site, creating, when applicable and possible, logs (activity records) that will contain information such as:IP address, Actions performed in the service, Date and time of each action, Data about the device used, including operating system version, browser and geolocation. Additionally, we may use our own or third-party technologies to monitor your activities while you access our site, such as: Cookies, Web beacons, Analytics tools, Pixel, And similar ones.

10.1 Cookies

For administrative purposes, KLAVE may use "cookies" on its platforms. These files help improve the user experience, allowing the system to remember settings and preferences. The user has the option to, at any time, configure their browser to be notified when cookies are activated or even completely deactivate them, according to their preference. There are different types of cookies that KLAVE may use, and each one has a specific purpose:

  • Necessary Cookies: They are essential for the platforms to function. Without these cookies, some functionalities may be compromised, making it impossible to use the service adequately. They can collect information such as system preference settings, history of actions performed, and IP number.
  • Third-Party Cookies: Used to improve platform performance and optimize marketing strategies, with support from independent partner companies, such as Google Analytics and Google Ads. These cookies can collect data such as visit time, accessed pages, downloads made, completed forms, and IP number.
  • Preference Cookies: They function to remember user preferences, even after closing the browser or device reinitialization. They can store information such as access password (if this option has been activated), searched words, visited pages, and IP number.

10.2 Web Beacon

A web beacon is a technique used to track visitors to a web page, allowing the identification of user behavior when interacting with different sites or servers.

10.3 Analytics Tools

Analytics tools are used to collect information about your navigation, such as pages visited, the moment each page is accessed, and other sites visited previously, among other metrics related to online behavior.

10.4 Pixel

A "Pixel" is a small piece of code inserted into a web page that tracks specific actions or interactions of a user on a site. It helps to understand the performance of advertising campaigns and optimize ad targeting based on browsing behavior.

11. SECURITY MEASURES

We employ technical and organizational measures designed to protect personal data from unauthorized access and situations of destruction, loss, misplacement, or alteration of this data. The measures we use take into consideration the nature of the data, the context and purpose of processing, the risks that a potential violation would generate for user rights and freedoms, and the standards currently employed in the market by companies similar to ours. Among the measures adopted by us, we highlight the following:

  • Our users' data is stored in a secure environment
  • We limit access to our users' data so that unauthorized third parties cannot access it
  • We maintain records of all those who have, in some way, contact with our data
  • Data access is only allowed after authentication through login and password

12. DATA RETENTION

KLAVE has established data retention periods based on processing objectives and considering the company's legal obligations, that is, the period we retain your personal data until the purposes set out in this Privacy Policy are achieved, or as long as legal and/or contractual relationships between the parties are maintained. After the contract ends, KLAVE keeps users' data for a period of 5 (five) years. After this period, the data is deleted or anonymized.

If there is any legal or regulatory justification, the data may remain stored, even if the purpose for which it was collected or processed has been exhausted.

Once the processing is completed, observing the provisions of this section, the data is deleted or anonymized.

13. CONSENT

Users declare themselves aware and expressly, freely, informedly and unequivocally agree that, as a result of this Privacy Notice and the express acceptance given prior to registration on the platform, KLAVE may process their personal data, including sensitive personal data, within the limits explained in this document, solely and exclusively to comply with their intended purpose, as well as, in compliance with all applicable legislation on information security, privacy and data protection, including, but not limited to Law No. 13,709/2018 (General Data Protection Law), under penalty of liability of the infringing party for losses and damages.

14. LEGITIMATE INTEREST

In this Privacy Notice, we explain that some personal data may be processed by KLAVE to serve our legitimate interests or those of third parties. In these situations, we carry out a detailed and careful analysis to assess whether the interests are truly legitimate, whether the processing and personal data are necessary to achieve these objectives and, furthermore, whether they comply with your fundamental rights and freedoms as a data subject.

15. PRIVACY POLICY CHANGES

KLAVE may revise and update this Privacy Policy periodically to ensure that it complies with company practices and applicable legislation. Whenever there are significant changes in how we process personal data, users will be informed through available communication channels, such as email or SMS.

The user must provide new express consent to continue using KLAVE's services after the changes take effect. If you do not agree with the changes, the user must cease using the platform, contact us to close their account and, if necessary, request the deletion of their personal data and revocation of consent.

16. CONTACT US

According to the LGPD, KLAVE is the "Controller" of your personal data. If you have any questions or need to contact us about the processing of your data, you can contact our Data Protection Officer (DPO) through the following channels:

We are available to clarify any doubts and ensure that you have full control over your personal data.

17. GENERAL PROVISIONS

17.1 Although we strive to provide adequate security for the information in our possession and control, it is important to be aware that no system is completely immune to possible security breaches. We take reasonable measures to protect your data, but we cannot guarantee total security against all forms of theft or improper use of information.

17.2 KLAVE is not responsible for access, use, or disclosure of information that occurs as a result of theft or disclosure (intentional or negligent) of passwords by the Controller. Even though we adopt rigorous security measures, total confidentiality of information cannot be guaranteed.

17.3 The Privacy Policy of KLAVE does not apply to how third parties define or use personal data. We suggest that you read the privacy policies of these third parties and understand your privacy rights before interacting with them.

17.4 If any security incident occurs that may generate relevant risk or damage to any of our users, we will notify the affected parties and the National Data Protection Authority about the occurrence, in accordance with the provisions of the General Data Protection Law.

17.5 Employees and contractors who improperly use this information, violating this Privacy Policy, will be subject to the penalties of our company's disciplinary process, as well as the penalties provided for in civil and criminal legislation.

17.6 If, for any reason, a competent court finds that any provision of this Privacy Policy (or any part thereof) is unenforceable, that provision (or any part thereof) shall be applied to the maximum extent permitted, in order to reflect the intent of KLAVE's Terms, and the remaining provisions of this Term shall remain in full force and effect.

17.7 Any tolerance to a breach of this contract shall be considered mere liberality, not being considered novation, nor becoming part of these Terms.

17.8 The Court of the City of Itajaí, State of Santa Catarina, is elected to resolve any conflicts arising from this instrument, waiving any other, however privileged it may be.

17.9 After the presentation of the terms and conditions of the Privacy Policy, the user must expressly agree to its provisions to effectively use the service offered.

Itajaí/SC, updated on January 28, 2025.

KLAVE

CNPJ nº: 42.355.765/0001-94