NETWORK KING’S PRIVACY POLICY

Version 1.0. First Version: June 1, 2020.
Version 1.01. Updated: May 04, 2021.

Welcome to Network King! Thank you for using Network King!

When you use Network King, you trust us with your data and information. We are committed to maintaining that trust.

Accordingly, this Privacy Policy (“Policy”) explains in a clear and accessible manner how your information and data will be collected, used, shared and stored through our systems.

YOUR ACCEPTANCE OF OUR POLICY WILL BE MADE WHEN YOU ACCESS OR USE NETWORK KING’S WEBSITE, APPLICATION OR SERVICES. THIS WILL INDICATE THAT YOU ARE AWARE OF AND IN FULL AGREEMENT WITH HOW WE WILL USE YOUR INFORMATION AND DATA.

This Policy is divided as follows for ease of understanding:

1. What information Network King collects
2. How Network King uses the information collected
3. How, when and with whom Network King shares your information
4. What rights you have over the information we collect
5. How Network King protects your information
6. Updates to this privacy policy
7. Applicable Law

This document should be read in conjunction with our Terms of Use, also available here on the website, which contain an overview of our platform. If you have any questions or need to address any issues related to this Policy, please contact us at network-king@theshift.info.

1. INFORMATION WE COLLECT

We collect the following types of information:

• Registration data to receive the newsletters. When you register with Network King, you provide us with information such as e-mail (login), password, first and last name, company, job title and cell phone.
• Subscription data for access to exclusive site content. When you subscribe to Network King, you provide us with information such as e-mail (login), password, first name, last name, company, job title, cell phone and payment information (address, CPF, credit card).

1.1 Information generated when you use our services.

We collect the following generated information:

• Access Logs. Network King automatically collects records of access to the website and newsletters received by email, which include the IP address, with date and time, used to access Network King. This data is mandatory to collect in accordance with Law 12,965/2014 but will only be provided to third parties with your express authorization or through judicial demand.
• Usage Data. We collect information regarding your interactions on Network King, such as your browsing, the pages or other content you access or create, your searches, participation in surveys or forums and other actions.
• Payment Data. When you make payments at Network King, payment data such as the date and time, amount and other details of the transaction may be stored and used for fraud prevention purposes. This enables us to provide you with a safe and secure environment in which to transact business.
• Device characteristics. Like most applications, in order to operate, Network King automatically collects data regarding your computer or mobile device’s characteristics, including its operating system, version, hardware information, language, internet signal and battery.
• Communications with Network King. When you communicate with Network King, we collect information regarding your communications, including metadata such as date, IP and time of communications and all content as well as any information you choose to provide.
• Cookies and Similar Technologies. We use cookies, which are text files generated and stored on your browser or device by websites, applications and online advertisements. Cookies may be used for the following purposes: to authenticate your login information, your subscriptions and to remember your preferences.

2. HOW WE USE YOUR INFORMATION

We value your privacy very much. Therefore, all data and information about you is treated as confidential, and we will only use it for the purposes described here and authorized by you, mainly so that you can use Network King fully, always aiming to improve your user experience.

2.1 Authorized uses

In this way, we may use your data to:

• Allow you to access and use all of Network King’s features;
• Send you messages regarding support or service, such as alerts, notifications and updates;
• To communicate with you regarding products, services, promotions, news, updates, events and other matters which may interest you;
• Analyze user traffic in our applications;
• Perform targeted advertising according to your tastes, interests and other collected information;
• Customize the service to suit your tastes and interests;
• We create new services, products and features;
• Detection and prevention of fraud, spam and security incidents;
• Verify or authenticate the information you provide, including by comparing it with data collected from other sources;
• Better understand our users’ behavior and build behavioral navigation profiles;
• For any other purpose that is made explicit at the time of data collection;
• Fulfill legal obligations.

Eventually, we may use data for purposes not foreseen in this privacy policy, but these will be within your legitimate expectations. The eventual use of your data for purposes that do not comply with this prerogative will be done only with your prior authorization.

2.2 Data Exclusion

All data collected will be deleted from our servers when you request it, via a free and easy procedure, or when it is no longer necessary or relevant to provide you with our services, unless there is any other reason for its maintenance, such as any legal obligation to retain data or the need to preserve it to protect the rights of Network King.

In cases where you request deletion of your data, this will be done promptly and to the extent possible.

2.3 Monitoring

Network King reserves the right to monitor the entire platform, primarily to ensure that the rules described in our Terms of Use are being observed or that there is no violation or abuse of applicable laws.

2.4 User exclusion

Network King reserves the right to exclude a particular user, of whatever type, if this Policy or the Terms of Use are not respected. We value positive relationships with our users. As such, we recognize that they have the right to seek to understand the reasons and even contest them. This can be done through the following e-mail address: info@network-king.net

3. INFORMATION SHARING

Network King does not share its database with commercial partners or advertisers. Any communication with our users is done through our own tools. However, Network King may share the information it collects with commercial partners and advertisers in an anonymous way, for statistical purposes and behavior analysis, but always aiming to preserve your privacy. Through this document, you expressly authorize such sharing.

Network King allows other companies and ad networks to advertise on our platform using different technologies. Therefore, you may occasionally receive directly in your browser, email or application advertisements, content and links displayed in a personalized manner according to your interests and behaviors on our platform or other services with which you interact. To this end, data may be shared between Network King and these other companies, particularly unique identifiers, IP addresses, cookies and Java Scripts, which may be used to measure the effectiveness of online advertising. You hereby expressly consent to such sharing. However, Network King is not responsible for the acts, advertisements and content generated by our business partners and ad networks, and this Policy does not apply to them, since Network King does not control them. We encourage you to access and read the privacy policies of companies with which you may interact.

All data, information and content about you may be considered assets in the event of negotiations to which Network King is a party. We therefore reserve the right, for example, to include your data among the assets of the company if it is sold, acquired or merged with another company. You hereby agree and are aware of this possibility.

Network King reserves the right to provide you with data and information about you, including interactions with you, if legally required to do so, if necessary for the company to comply with national laws or if you expressly consent.

4. RIGHTS OF THE HOLDERS

You can always choose not to disclose your data to us, but please keep in mind that some of this data may be necessary in order to use the features of our applications. Regardless of this, you will always have rights regarding privacy and protection of your personal data.

Accordingly, below we summarize all the rights you have under Brazil’s data protection laws and the General Data Protection Law (“LGPD”), namely:

• Right of Access. This right enables you to request and receive a copy of the personal data we hold on you.
• Right of rectification. This right enables you, at any time, to request the correction and/or rectification of your personal data if you identify that some of it is incorrect. However, in order to effect such a correction, we will need to check the validity of the data that you provide to us. You can rectify some of your personal data directly through the form available on our site or by e-mailing info@network-king.net.
• Right of Exclusion. This right allows you to request that we delete the personal data we have about you. All data collected will be deleted from our servers when you request it or when it is no longer necessary or relevant to provide you with our services, unless there is any other reason for its retention, such as any legal obligation to retain the data or the need to preserve it to protect the rights of Network King. To change your personal information or delete it from our database, simply send an email to info@network-king.net.
• Right to object to processing. You also have the right to object to where and in what context we are processing your personal data for different purposes. In certain situations, we may demonstrate that we have legitimate reasons for processing your data that override your rights, if, for example, it is essential for the provision of our applications.
• Right to request anonymization, blocking or deletion. This right allows you to ask us to stop processing your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) when you need the data to be kept even if we no longer need it, as necessary to establish, exercise or defend legal claims; or (c) if you object to the use of your data, but in this case, we need to check whether we have legitimate reasons to use it.
• Right to portability. We will provide to you or to the third parties you choose your personal data in a structured and interoperable format.
• Right to Withdraw Your Consent. You have the right to withdraw your consent in relation to the terms of this Privacy Policy. However, this will not affect the legality of any processing previously performed. If you withdraw your consent, we may not be able to provide certain services.
• Right to review automated decisions. You also have the right to request a review of decisions made solely on the basis of automated processing of your personal data which affect your interests, including decisions aimed at personal, professional, consumer and credit profiling and/or aspects of your personality.

We may need to ask you for specific information to help us confirm your identity and secure your right to access your personal data (or to exercise your other rights). This is a security measure to ensure that personal data is not disclosed to any person who is not entitled to receive it. We may also contact you for further information regarding your request in order to expedite our response. We attempt to respond to all legitimate requests within 5 (five) business days. Occasionally, it may take longer than 5 (five) days if your request is particularly complex or if you have made multiple requests. In this case, we will communicate with you and keep you updated on the progress of your request.

If you have any questions regarding these issues and how you can exercise these rights, feel free to contact us at network-king@theshift.info.

5. INFORMATION SECURITY

All your data is confidential, and only persons with the proper authorizations will have access to it. Any use of it will be in accordance with this Policy. Network King will use commercially reasonable efforts to ensure the security of our systems and your data. Our servers are located in different locations to ensure stability and security and can only be accessed through previously authorized communication channels.

All your information will be encrypted, whenever possible, if it does not make your use of the platform unfeasible. At any time you, may request a copy of your data stored on our systems. We will retain data and information only until such time as it is necessary or relevant for the purposes described in this Policy, or in the case of periods predetermined by law, or until such time as it is necessary for the maintenance of Network King’s legitimate interests.

Network King considers your privacy to be extremely important, and we will do everything in our power to protect it. However, we cannot guarantee that all data and information about you on our platform will be free from unauthorized access, especially if there is improper sharing of credentials needed to access our application. Therefore, you are the only responsible for keeping your access password in a safe place and sharing it with third parties is prohibited. You agree to notify Network King immediately, through secure means, of any unauthorized use of your account as well as unauthorized access to it by third parties.

6. UPDATES TO THE PRIVACY POLICY

Network King reserves the right to change this Policy as often as necessary to provide you with more security and convenience and to continually improve your experience. That’s why it is very important to access our Policy periodically. To make it easier for you, we have indicated the date it was last updated on the top of the document. If we make material changes that require new consent from you, we will post a new privacy policy, again subject to your consent.

7. APPLICABLE LAW

This document is governed by and shall be interpreted in accordance with the laws of the Federative Republic of Brazil. The District Court of São Paulo, São Paulo, is hereby elected as the competent jurisdiction to settle any issues that may arise from this document, expressly waiving any other, no matter how privileged it may be.

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