Version 1.0.0 
By the present private instrument, henceforth called "PRIVACY AND DATA PROCESSING POLICY", KVOLTZ GREEN ENERGY LTDA, limited liability company registered under the tax ID 47940602000192, hereinafter referred to as "KVOLTZ", describes, through the terms mentioned below, to any person, qualified in accordance with the data and information provided at the time of his/her respective registration in the "PLATFORM" (the electronic sites whose domains are owned by KVOLTZ itself: https://www.kvoltz.info, https://www.kvoltz.com, as well as all its subdomains and tabs, and the mobile apps for Android or IOS) for creating a virtual account, as well as to any other third parties who access it in any way without even registering, what personal data are collected, how they are used, stored and shared, and what rights their holders have in relation thereto. 
Clause 1 (first) - Types of Data Collected 
1.1 At the time of registration, as well as for any and all subsequent navigation on the PLATFORM, with the hiring of any service or purchase of any product, contacting through support and service channels or even just participating in surveys and promotions, several types of data can and are collected by KVOLTZ, through sharing by the holder himself or by third parties authorized by him, such as 
(a) personal and contact information: In case of natural person, 1) full name; 2) CPF inscription and RG identity card numbers; 3) date of birth; 4) facial biometric data; 5) contact phone number; 6) home and electronic mail address - e-mail; 7) degree of political exposure; If legal entity, 1) corporate name and trade name; 2) CNPJ registration number; 3) contact telephone number; 4) home and e-mail address; 5) full qualification described above of the natural person of the managing partner or non partner manager responsible for the registration; 
b) Information resulting from the use and navigation on the PLATFORM: 1) virtual account access data and creation date, with login name, password in encrypted format and its respective security questions for reminder or substitution; 2) service and support history; 3) access to contact list, if voluntarily allowed; 
c) Technical information about navigation and which hardware is used: 1) Specifications, type and system operational version of the cell phone model or computer equipment used; 2) registration of the IP address used to connect you to the Internet; 3) type and version of the web browser used; 4) fixed geographic location and also in real time; 5) URL, network connection and provider information; 
d) Marketing and support information: 1) Feedbacks, evaluations, comments and grades for services rendered or products sold; 2) Interactions and conversations held with KVOLTZ support chat staff; 
e) Information generated in third-party social networks: 1) Content created and published in third-party social networks (Facebook, Instagram, TikTok, LinkedIn, etc.) in which there are, in any way, mentions or interactions with KVOLTZ or that is shared with it voluntarily, such as texts, comments, articles, photographs, videos, stories or other similar content and media; 2) Information that is already publicly available or that has been made public in a spontaneous way by its holder; 
1.1.1 For full validation of the information mentioned in paragraph "a", in case of registration of an individual, a photographic self-portrait (selfie) of the individual and photocopies, through the attachment of photographic captures made on the cell phone or computer used to access the virtual account itself or by attaching the digital file, if they already have them in their media, are collected: 1) RG, CPF and/or CNH; 2) Proof of residence. In case of registration of a legal entity, a photographic self-portrait (selfie) of the managing partner or non-member administrator who will access and manage the virtual account and photocopies, by attaching photographic captures made on the cell phone or computer used to access the virtual account itself or by attaching the digital file, if they already have them on their media, of: 1) RG, CPF and/or CNH of the managing partner or the non-partner administrator who will access and manage the virtual account; 2) CNPJ card, QSA, contract or bylaws; 3) mandate instrument of the non-partner administrator, if he has not been expressly appointed in the contract or bylaws itself; 
1.2 Demographic and interest information (e.g., demographic data, behavioral habits or characteristics and Internet routine, age range, gender, business segment, customer niche, etc.) and how the PLATFORM is used, which customer-site or visitor-site interactions, e.g., which actions were taken, which links were clicked on, which tabs or pages were opened and for how long they were viewed) are currently collected by KVOLTZ through cookies. 
1.2.1 Cookies are text files placed on your computer to automatically collect standard Internet log information and website visitor behavior information. 
1.2.2 The visitor or customer can manually configure his browser to notify him when he receives a cookie. This allows them to make an autonomous decision whether or not to accept it. Alternatively, it is possible to disable all cookies in the browser settings. However, some of the services, products and features offered by KVOLTZ through the website may not function properly if cookies are disabled. 
1.2.2.1 Cookies may be either owned cookies or third party cookies: 
(a) Own cookies - cookies that the website stores on your computer; 
b) Third-party cookies - cookies stored on your computer by the website, but by third parties, such as Google; 
1.2.2.2 Cookies can also be session, performance, functionality, and social analytics cookies: 
(a) session cookies are essential to allow navigation on the PLATFORM and use of its features. Without these cookies, the requested services cannot be provided. They are deleted when the browser is closed. These are primary cookies; 
b) Performance cookies collect anonymous data on how visitors and customers use the KVOLTZ site. They allow you to recognize and count the number of visitors and customers and to see how everyone browses and uses it, when they are using it and the approximate regions from which they are browsing. These are primary cookies;
c) Functionality cookies allow the PLATFORM to remember the choices a visitor or customer makes (such as their username, language, or the region they are in) and provide enhanced, more personal features. These cookies may also be used to remember changes made to text size, fonts, and other parts of the web pages that are customizable. The information these cookies collect may be anonymous and cannot track browsing activity on other sites. They are deleted when you log out. These are first-party cookies; 
d) Social analytics cookies allow KVOLTZ and ad partner companies to provide more relevant information to the visitor or customer according to their interests and they can also connect you to social media networks. These are cookies that can be either primary or third party and are kept on your device until they expire or are manually deleted; 
1.2.2.3. when you start browsing the KVOLTZ website, a pop-up message will be displayed notifying the visitor or customer which cookies are used and that he can accept them fully, reject them fully or manually configure which ones will be accepted and which ones rejected. 
1.3 Currently, KVOLTZ does not collect any information defined as sensitive data. When there is a legitimate interest or it is necessary to collect sensitive personal data for any reason, prior, express and formal consent will be requested for any processing that is voluntary (e.g. for marketing purposes). The collection and processing of sensitive personal data for other purposes will only occur in the event of (i) detection and prevention of crime; and (ii) compliance with applicable law or court order. 
Clause 2 (second) - Treatment of Collected Data 
2.1 In addition to the purposes of cookies already detailed simultaneously with their very conceptualization in clause 1.2, the purposes for which KVOLTZ collects the data mentioned in clause 1.1 are described below: 
(a) personal and contact information is intended for: 1) carrying out the registration and creation of profile and virtual account of the data holder, with the identification, authentication and verification of requirements for hiring the services and purchase of products and consequent provision and sale of them by KVOLTZ; 2) meeting requests and questions, contact by phone, email, SMS, WhatsApp, or other means of communication, including for sending notifications or push when there is use of the services or purchase of products; 4) marketing, prospecting, market research, opinion polls and promotion of services, including making offers and sending information on products, services, news, features, content and other relevant events; 5) regular exercise of rights, including the possibility of submitting documents in legal and administrative proceedings, if necessary, collaboration or compliance with court order, competent authority or supervisory body or legal or regulatory obligation; 6) investigations and adoption of measures to prevent and combat illegalities, fraud, corruption, bribery, financial crimes, money laundering, terrorism financing and ensuring the security and financial system; 7) legitimate interest of KVOLTZ in the constant development and improvement of the PLATFORM and the improvement of its services and products; 
b) The information resulting from the use and navigation on the PLATFORM is destined for: 1) provision of the contracted services; 2) fulfillment of requests and questions, contact by phone, email, SMS, WhatsApp, or other means of communication, including for sending notifications or push when there is use of services or purchase of products; 3) marketing, prospecting, market research, opinion polls, and promotion of services, including enabling offers and sending information about 
products, services, news, features, content and other relevant events; 4) regular exercise of rights, including the possibility of submission of documents in legal and administrative proceedings, if necessary, collaboration or compliance with court order, competent authority or supervisory body or legal or regulatory obligation; 5) investigations and adoption of measures to prevent and combat illegalities, fraud, corruption, bribery, financial crimes, money laundering, terrorism financing and ensuring the security and financial system; 6) prevention and resolution of technical or security problems; 7) technical improvement of the services provided, with the development of new products and services to be offered and the generation of knowledge for innovation, in addition to the performance of tests; 8) monitoring the use and performance of the services; 9) legitimate interest of KVOLTZ in the constant development of improvements to the PLATFORM and the improvement of its services and products; 
c) The technical information about navigation and which hardware is used is destined to: 1) constant development of improvements for PLATFORM, with the analysis of its daily operation in the equipment to verify possible errors or bugs in its programming; 2) improvement of the provision of services and the sale of products, with the generation of administrative and organizational reports; 3) recommendation of new services or functionalities; 4) display of advertising; 5) generation of statistics, studies, research and surveys pertinent to the activities and behavior in the use of the services; 6) prevention and resolution of technical or security problems; 7) investigations and adoption of measures to prevent and combat illicit acts, fraud, corruption, bribery, financial crimes, money laundering, financing of terrorism and ensuring the security and safety of the financial system; 8) regular exercise of rights, including the possibility of submitting documents in legal and administrative proceedings, if necessary, collaboration or compliance with court order, competent authority or supervisory body or legal or regulatory obligation; 9) legitimate interest of KVOLTZ in the constant development of improvement to the PLATFORM and the improvement of its services and products; 
d) The marketing and support information is aimed at 1) optimization of the provision of services and products by KVOLTZ; 2) answering requests and questions, contact by phone, email, SMS, WhatsApp, or other means of communication, including for sending notifications or push when there is use of the services or purchase of products; 3) marketing, prospecting, market research, opinion polls and promotion of products and services, including making offers and sending information about products, services, news, features, content and other relevant events for the maintenance of customer-KVOLTZ relationship; 4) recommendation of new services, products or features; 5) display of advertising 6) generation of statistics, studies, research and surveys related to the activities and behavior in the use of products and services; 7) prevention and resolution of technical or security problems; 8) constant development of improvements for the PLATFORM, with the analysis of its daily operation to check for possible errors or bugs in its programming; 9) regular exercise of rights, including the possibility of submitting documents in legal and administrative proceedings, if necessary, collaboration or compliance with court order, competent authority or supervisory body or legal or regulatory obligation; 10) legitimate interest of KVOLTZ in the constant development of improvements to the PLATFORM and the improvement of its services and products; 
e) The information generated in third-party social networks is intended for: 1) re-sharing by KVOLTZ of any such content for any lawful business and commercial purposes, such as the dissemination of its services, products, contests, awards and other promotions and institutional engagement; 2) marketing, prospecting, market research, opinion research and promotion of products and services, including enabling offers and sending information on services, news, features, content and other events relevant to maintaining the relationship customer-KVOLTZ; 3) recommendation of new services, products or functionalities; 4) exhibition of publicity; 5) generation of statistics, studies, researches and surveys pertinent to the activities and behavior in the use of products or services; 6) regular exercise of rights, including with the possibility of presenting documents in judicial and administrative processes, if necessary, collaboration or fulfillment of judicial order, of competent authority or supervisory body or of legal or regulatory obligation; 
Clause 3 (third) - Sharing of Processing 
3.1 In addition to the use of the data mentioned in clause 1.1 and 1.2 by KVOLTZ itself, they may be shared with the following types of third parties: 
(a) Service Providers: External companies and partners of KVOLTZ that assist in the provision of services or sale of products; 
b) Information technology service providers; 
c) Customer service and communication companies; 
d) Statistical, research, marketing and advertising service providers; 
e) Credit analysis and financial services agencies, debt collection and prevention of fraud, corruption, bribery, money laundering, terrorism financing and financial crimes; 
f) Accounting and law firms; 
g) Authorities and regulatory bodies; 
3.1.1 The third parties described in points "a", "b", "c", "d", "e" and "f" are only authorized to access the data for specific tasks, which are requested on the basis of direct instructions from KVOLTZ's own persons with management power. They are contractually obliged to keep the shared data secure, confidential and secret, and in the event of a leak are jointly and severally liable for the damage caused. 
3.1.2. The sharing with third parties described in lines "a", "b", "c", "d", "e" and "f" is intended for 1) provision of the contracted services or sale of the purchased products; 2) answering requests and doubts, contact by telephone, e-mail, SMS, WhatsApp, or other means of communication, including for sending notifications or push when there is use of the services or purchase of products; 3) sending communications in general; 4) marketing, prospecting, market research, opinion polls and promotion of products and services, including making offers and sending information on services, news, features, content and other relevant events to maintain the relationship customer-KVOLTZ; 5) investigations and adoption of measures to prevent and combat illegalities, fraud, corruption, bribery, financial crimes, money laundering, terrorism financing and ensuring the security and financial system; 6) prevention and resolution of technical or security problems; 7) generation of statistics, studies, research and surveys related to the activities and behavior in the use of products and services; 8) debt collection; 9) constant development of improvements to the PLATFORM, with the analysis of its daily operation to check for possible errors or bugs in its programming;  10) regular exercise of rights, including the possibility of submitting documents in legal and administrative proceedings, if necessary, collaboration or compliance with court order, competent authority or supervisory body or legal or regulatory obligation; 11) legitimate interest of KVOLTZ to constantly develop and improve the PLATFORM and the improvement of its services and products; 
3.1.3. Sharing with authorities and regulatory bodies is intended for: 1) investigations and adoption of measures to prevent and combat illicit, fraud, corruption, bribery, financial crimes, money laundering, financing of terrorism and ensuring the security and the financial system; 2) regular exercise of rights, including with the possibility of submission of documents in judicial and administrative proceedings, if necessary, collaboration or compliance with a court order, competent authority or supervisory body or legal or regulatory obligation; 
3.2 If KVOLTZ is acquired by, or merged with, another company, including by reason of bankruptcy, the sharing of the data mentioned in clauses 1.1 and 1.2 with the legal successors will be done in strict compliance with the requirements of the legislation in force.  
3.3 The disclosure of data to third parties will also take place to enforce the terms of any contract, agreement or the terms of use of the PLATFORM, in accordance with current legislation. 
3.4 Upon the request of the owner of the collected data, it will also be possible to share it with any third party the owner indicates as reliable. 
3.5. When using the PLATFORM, it may be possible to redirect to other apps or third party websites. After redirection, privacy practices will be governed by the privacy policies and terms of use of these third parties. KVOLTZ cannot control or be responsible for their privacy practices and content. Therefore, you are encouraged to carefully read the applicable privacy policies to understand how they collect and process data. 
3.5.1 Necessarily, for the purchase of KVOLTZ tokens, there will be a redirection to the wallet app as Metamask, a partner technology company responsible for developing such cryptoactive products.  Despite the existing business relationship, the legal entities are independent and have no link greater than the provision of technological development services. Therefore, in any case, clause 3.5 remains applicable in this situation. 
Clause 4 (fourth) - Storage and Termination of Data Processing 
4.1 As long as the data subject remains registered with the PLATFORM or, at least, has already submitted his/her data for identification, authentication and validation, or simply has not yet reconfigured his/her cookie permissions, deleted them manually or logged out, the information collected shall be kept in a secure and controlled virtual environment, stored in the digital cloud AWS (Amazon Web Services). 
4.2 In accordance with current legislation, KVOLTZ may use the data mentioned in clause 1.1 and 1.2 for as long as necessary to fulfil the purposes for which they were collected, see clauses 2.1 and 1.2.2.2, or to comply with applicable legal requirements. 
4.3 Upon the irrevocable and irreversible giving up of the use of the PLATFORM, with the cancellation and exclusion of the registration, the storage and treatment of the data mentioned in clauses 1.1 and 1. 2 may be kept for an additional period of time of ten (10) years or for the exact mandatory statute of limitations, whichever is longer, for the purposes of auditing and fulfilling legal or regulatory obligations, for the regular exercise of rights or also for the necessary period according to the legal basis justifying the retention of data, for example, to preserve rights in case of lawsuits filed against KVOLTZ. Except in these cases, the data processing will be terminated and the data will be deleted within the scope and technological limits possible. 
Clause 5 (fifth) - Rights of Data Subjects 
5.1 All data subjects are entitled to confirm the existence, access, review, modify and/or request an electronic copy of the information of the data being collected by KVOLTZ and/or shared by it with third parties, as well as which third parties they are. 
5.1.1 Personal and contact information may be changed or rectified at any time, in the personal profile tab in the PLATFORM menu, if any, or while this function is not enabled, through the support chat. 
5.2 If the consent of the data subject is necessary to access or use a particular service or purchase a product, it is possible to ask KVOLTZ to clarify whether it is possible to provide this service or purchase the good without consent for the processing of personal data, or what the consequences of not providing consent are in this case. 
5.3 If any personal data is processed unnecessarily, in excess of the purpose for which it is intended or in non-compliance with the LGPD, it is possible to request that KVOLTZ anonymize, block or delete such data, provided that the excess, lack of necessity or non-compliance with the law is effectively established. 
5.4 If consent has been given to process personal data for specific purposes (and not necessary for the provision of the service or sale of products), it is possible to request the deletion of such personal data. 
5.5 At any time, it is possible to limit the use and disclosure, or revoke consent to any of the processing activities of the collected data, unless they are intended for a purpose that is mandatory for the provision of the services or sale of the products of KVOLTZ or if they are imperative and provided for in the legislation in force. 
5.6 If consent has been given to process personal data, it is possible to request the revocation of this consent. The revocation of the consent may result in the impossibility of using some functionalities of the website, or even in the termination of the services provided, but does not prevent the use of (i) anonymized data; and (ii) data whose processing is based on another legal hypothesis foreseen in the LGPD. 
5.7 According to the current legislation, these rights may be exercised through the communication channels detailed in this PRIVACY AND DATA PROCESSING POLICY, requiring the provision of means of identification, such as CPF/CNPJ, name, RG, or other suitable means, depending on your needs. 
5.7.1. The communication channels are 
a) Website Support Chat;
b) E-mail: dpo@kvoltz.com; 
5.7.2 Whenever a request is submitted without the provision of evidence capable of proving the legitimacy of the holder of the data, the request will be automatically rejected. 
Clause 6 (sixth) - General Aspects of Data Collection 
6.1 The data may be accessed by KVOLTZ collaborators or employees, provided that they are authorized and that they need to have access to such information, due to their function performed in the company. All of them are obliged to keep the data accessed in strict confidentiality and secrecy, under penalty of configuration of just cause for dismissal and civil liability for damages caused. 
6.2 The data is duly stored on the AWS server (Amazon Web Services), a world reference in cyber security. 
6.2.1 The personal data collected may be transferred abroad, for example when they are stored by KVOLTZ in cloud computing servers located outside Brazil, as is the case of AWS. To this end, KVOLTZ observes all requirements established by current legislation and adopts the best security and privacy practices to ensure the maximum integrity and 
integrity and confidentiality of your personal data. 
6.3 This PRIVACY AND DATA POLICY may be changed at any time and its modifications shall become effective on the date of publication on the PLATFORM. Continued solicitation of services or purchase of products from KVOLTZ results in automatic acceptance of the new version of these provisions. 
6.4 By reading this PRIVACY AND DATA PROCESSING POLICY and clicking, at the end, on "I have read, I am aware of the conditions of processing of my personal data and provide my consent, where applicable", the data subject consents to the processing of personal information in the ways indicated herein. 
6.4.1 In the event that changes to this PRIVACY AND DATA PROCESSING POLICY result in changes to personal data processing practices that depend on the consent of the data subject, consent will be sought with the new terms in relation to the data processing and purposes indicated. 
6.5 Under Law No. 13,709/2018 (General Data Protection Law), KVOLTZ is considered a "Controller" of your personal data. If after reading this PRIVACY AND DATA PROCESSING POLICY any doubt still remains, or for any reason communication becomes necessary for matters involving personal data, you can contact us through the channels below: 
a) Website support chat; 
b) E-mail: dpo@kvoltz.com.