Privacy Policy
Ikonn considers the privacy and confidentiality of your personal data to be a very important matter.
Ikonn, in its role as Data Controller, values the trust of its customers and is committed to protecting their Personal Data.
The purpose of this Customer Privacy Notice is to provide information about what Personal Data we collect, use, share and disclose, as well as the purpose of processing this data and your rights as the data subject.
The terms and conditions of this Privacy Notice may be updated if there are changes to Ikonn's Personal Data processing activities, or if necessary to comply with a determination or new regulation by the National Data Protection Authority (“ ANPD ”).
Ikonn processes personal data always in accordance with the terms of Law 13.709 of August 14, 2018, the General Data Protection Law (“ LGPD ”), as worded in the law in force on the date of this policy, indicated at the end of the document.
1. Definitions
1.1 In this Privacy Notice, the terms below have the following meanings, unless expressly indicated otherwise:
Personal Data(s): Personal Data means any information that, directly or indirectly, alone or accompanied by other data, identifies or may identify a natural person. Examples of Personal Data include: name, CPF (Brazilian individual taxpayer registration number), CNH (Brazilian driver's license), CNPJ (Brazilian company taxpayer registration number), landline or mobile phone number, residential address, Internet Protocol (IP) number, email address, bank account number, financial profile, geolocation, among others. Sensitive Personal Data, as defined below, is included in this concept.
Sensitive Personal Data: means any information that reveals, in relation to a natural person, racial or ethnic origin, religious beliefs, political opinions, membership of a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data, as well as Personal Data whose processing reveals Sensitive Personal Data.
Security Incident(s) : means any and all situations, accidental or intentional, committed through negligence or intent, that cause, in relation to Personal Data: (i) destruction; (ii) loss; (iii) alteration; (iv) communication, dissemination or disclosure; or (v) unauthorized access.
Collaborators: These are employees of any hierarchical level, including temporary workers, apprentices, interns, and service providers of Ikonn.
Third Party(ies): means any Person, whether natural or legal, other than Ikonn, including Ikonn's subcontractors.
Data Subject(s) : means any natural person identified or identifiable by the Processing of Personal Data or Sensitive Personal Data.
Processing: means any and all operations performed on Personal Data or Sensitive Personal Data, including, but not limited to, collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
1.2 The terms below will have the same meaning attributed to them in the “ LGPD ”, namely:
Data Processing Agent: This refers to the Controller and the Operator.
National Data Protection Authority or “ ANPD ” : a public administration body responsible for ensuring, implementing, and overseeing compliance with the “ LGPD ” throughout the national territory.
Controller: means the natural or legal person, governed by public or private law, who is responsible for decisions regarding the processing of personal data.
Operator: means the natural or legal person, governed by public or private law, who processes personal data on behalf of the controller.
Data Protection Impact Assessment Report: This refers to the Controller's documentation that describes the Personal Data Processing processes that may generate risks to civil liberties and fundamental rights, as well as measures, safeguards, and risk mitigation mechanisms.
2. How we collect the data
2.1 Data is collected when entered or submitted by the Customer themselves when accessing or requesting our products or services through our customer service channels, websites, and applications.
3. For what purpose do we process the data?
3.1 The data is collected by Ikonn for the following purposes:
(i) To provide customer service, including service activation;
(ii) Conducting direct sales to consumers in cases provided for by law;
(iii) Conducting promotions, offers, providing discounts from partner companies to Ikonn customers, and marketing actions, communicating with winners, and organizing events;
(iv) Conducting market research and satisfaction surveys;
(v) Handling requests for quotes, services or support through the Ikonn website;
(vi) Analysis of indicators and implementation of improvements in Ikonn's processes;
(vii) Conducting audits;
(viii) Compliance with legal obligations, court decisions, requests from police authorities or the regular exercise of rights in judicial, administrative or arbitration proceedings;
4. How the Data is handled
4.1 Without prejudice to the other provisions set forth in this Privacy Notice, Ikonn will process Customers' Personal Data in accordance with the following provisions:
(i) Adoption of technical, administrative and organizational measures appropriate to the nature of its activities, maintaining evidence of such compliance;
(ii) Guarantee of the confidentiality of Personal Data, by itself and its Employees;
(iii) Compliance with obligations arising from the status of Controller, relating to the reporting of Security Incidents and the preparation of a Personal Data Protection Impact Assessment Report, when applicable;
(iv) Respect for the rights of Data Subjects as provided for in the LGPD and respond to requests from Data Subjects;
(v) Providing Data Subjects with all mandatory information required by the LGPD and other applicable legislation;
5. Data Sharing
5.1 Clients acknowledge that Ikonn may share their Personal Data with Third Parties to fulfill the purposes described in Item 4, and that the sharing will be done through a Personal Data Processing and Protection Agreement (“ DPA ”) with the receiving Third Party.
5.2 Sharing Personal Data may include transferring Personal Data to other countries. If Ikonn carries out an international transfer of Personal Data, and if the country receiving the Personal Data does not have an adequate level of Personal Data protection as determined by the ANPD (Brazilian National Data Protection Authority), Ikonn will ensure that the international transfer of Personal Data occurs in accordance with one of the mechanisms provided for in the LGPD (Brazilian General Data Protection Law) and regulations issued by the ANPD.
6. Rights of the Data Subject
6.1 Ikonn guarantees to Clients, as Holders of Personal Data, the full and effective exercise of the rights provided for in the LGPD (Brazilian General Data Protection Law), to the extent applicable according to the circumstances, such as:
(i) Confirmation that we process the Client's Personal Data;
(ii) Access to Personal Data;
(iii) Correction of Personal Data that is incomplete, inaccurate or outdated;
(iv) Anonymization, blocking or deletion of unnecessary, excessive Personal Data or for which there is no legal basis for processing;
(v) Portability of Personal Data to another provider when regulated by the ANPD and trade secrets are observed;
(vi) Information about who we share Personal Data with;
(vii) Deletion of personal data processed with the Client's consent;
(viii) Revocation of the Client's consent (in specific cases where Personal Data is Processed based on the Client's consent);
(ix) Objection to the Processing of Personal Data in case of violation of the LGPD;
7. Storage of Personal Data
7.1 Ikonn securely stores Personal Data in its own data centers located in Brazil, as well as in third-party data centers located in other countries or in data centers provided by cloud computing service operators. Before sending your Personal Data for storage in other countries, we adopt the measures required by the LGPD (Brazilian General Data Protection Law) to ensure that it remains protected.
7.2 Ikonn adopts the best technical and administrative practices to protect Personal Data from unauthorized access, destruction, loss, alteration, communication or any form of inappropriate or unlawful processing.
7.3 At the same time, no platform is completely secure. If the Customer has any concerns or suspects that their Data is at risk, for example, if someone has gained access to their password, please contact us immediately.
8. Cookies, Web becon e Google Analytics
8.1 In some Personal Data Processing activities, Ikonn uses the following technologies:
(i) Cookies : A cookie is a small file added to the Client's device or computer to provide a personalized experience when accessing the platform. Cookies help analyze internet traffic or allow us to know when the Client has visited a specific website, as well as promote remarketing, fraud and risk analysis, and better user understanding.
(ii) Web beacon: A web beacon is a technique that allows you to map who is visiting a particular web page, identifying client behavior with different websites or web servers.
(iii) Google Analytics and Adwords: Ikonn uses a tool called “ Google Analytics ” to collect information about the use of the platform. Google Analytics collects information such as: how Customers visit this platform, which pages they visit and when they visit those pages, and other websites they used before coming to this platform. Ikonn uses the information obtained by Google Analytics only to improve this platform and its services. Google Analytics only collects the IP address assigned to the Customer and the date they visit this platform, rather than their name or other identifying information.
Although Google Analytics places a persistent cookie in the Client's web browser to identify them as a unique user the next time they visit this platform, the cookie cannot be used by anyone other than Google. The use and sharing of information collected by Google Analytics about visits to this platform are restricted and regulated by Google Analytics' terms of use and privacy policy. The Client can prevent Google Analytics from identifying them when they return to the platform by disabling cookies in their browser.
9. Personal Data Retention Period
9.1 Ikonn structures its operation in such a way that Customer Data is not kept in an identifiable manner for longer than necessary to achieve the purposes for which it is Processed. Customers acknowledge that Ikonn will retain Personal Data (i) for periods established by laws and regulations applicable to the activities carried out by Ikonn; and (ii) for the time necessary for the regular exercise of Ikonn's rights in judicial and administrative proceedings.
9.2 Ikonn collects data, for example, regarding the IP address of Clients, in case of online access, and Client access logs are stored for at least 6 (six) months, as determined by article 15 of Law No. 12.965/2014 (Marco Civil da Internet).
9.3 Ikonn may retain Personal Data in an anonymized form, meaning that it is not or cannot be linked to a Customer, for longer periods, for statistical analysis.
10. General Provisions
10.1 In the event of changes to the LGPD or publication of ANPD regulations, this Privacy Notice will be duly updated. Whenever Ikonn materially changes this Privacy Notice, these changes will be valid, effective and binding after: (i) being published on the Ikonn website, immediately informing users of the changes so that they are aware of them; (ii) being sent by email to Clients; and/or (iii) being communicated to Clients in any other way.
10.2 In cases where changes to this Privacy Notice result from changes in our Personal Data Processing practices that depend on the consent of Clients, Clients will be asked to consent to the new processing.
10.3 If the Customer has any questions or complaints regarding this Privacy Notice, they may contact our Data Protection Officer at contato@ikonn.com.br
10.4 This Privacy Notice will take effect upon the entry into force of the LGPD (Brazilian General Data Protection Law), and will remain in effect for the same period as the relationship established between the Client and Ikonn, and may be renewed under the same terms.