When you make a purchase or hire a service at KeeyPC, you provide us with some personal data to facilitate your operation. KeeyPC values the security of your data, respects your privacy, and is transparent with you. Therefore, we dedicate this document to explain how your personal data will be treated by KeeyPC and what measures we apply to keep them safe.

According to the definition provided by the General Data Protection Law ‘LGPD’ (Federal Law No. 13,709/2018), most of the time, we will be the controller of your information, thus responsible for defining what happens to this data and for protecting it.

To facilitate the understanding of this policy, every time you encounter the terms ‘KeeyPC,’ ‘we,’ or ‘our,’ we are referring to the controller of your personal data, i.e., directly referring to KeeyPC. Every time you read ‘user,’ ‘you,’ ‘your,’ or ‘yours,’ we refer to you, our customer or user of our platform.

Collected Data:

During registration:

• Full name;
• Email address;
• Cell phone number;
• Date of birth;
• Data related to your addresses.

During filling out the delivery location and payment method:

• Billing address;
• Delivery address;
• Credit card details when chosen as the payment method.

During the analysis and monitoring of your purchases or other financial transactions:

• Registration data;
• Product type;
• Quantity;
• Merchandise value (unit);
• Total value of the purchase or transaction;
• Nature of the financial transaction;
• Bank account information and other means used;
• Affiliation.

During platform navigation:

• IP address;
• Information about the device used for navigation;
• Searched or viewed products and categories;
• View count;
• Visited pages;
• Geolocation.

Other information that may be collected:

• Social login information if you register through a social media account, such as Facebook and Google, and authorize this collection;
• Information about you that has become public or is publicly available;
• Information received from partners for the delivery of purchased products on the platform, such as shipping information;
• Copies of documents sent by you, such as proof of residence, bank details, or a copy of an identification document, usually used to verify your registration.

How We Use Your Data:

We use personal data to ensure quality service and a better experience in your purchase. Below are the purposes for which we may use your personal data:

Registration data:

• To facilitate the provision of different services available on our platform.

To handle requests and inquiries in our Customer Service:

• To correctly identify the user;
• To send purchased products or offer communications about promotions and offers;
• To contact you when necessary, covering various subjects such as promotional communications, responses to inquiries, complaints, and requests, order updates, and delivery information;
• To assist in diagnosing and solving technical problems;
• To develop new features and improvements, enhancing your experience with our services;
• To conduct investigations and measures to prevent and combat illegal activities, fraud, financial crimes, and money laundering and/or terrorism financing;
• To ensure compliance with legal or regulatory obligations or to ensure the regular exercise of KeeyPC’s rights. In these cases, we may even use and present the information in legal and administrative proceedings, if necessary;
• To collaborate with the compliance of judicial orders, competent authorities, or regulatory bodies.

Geolocation:

• To identify the physical stores closest to you;
• To display personalized ads;
• To assist in analyses that can be used to protect your account and increase the security level of your registration data or prevent possible fraud.

Navigation Data:

• To assist in diagnosing and solving technical problems;
• To develop new features and improvements, enhancing your experience with our services.

With Whom We May Share Personal Data:

For the execution of the activities listed above, whenever necessary, we may share your personal data with service providers, partners, or regulatory bodies. We never commercialize personal data.

Here is a summary of these possibilities:

Service providers:

• To provide our products and services with quality, we collaborate with various service providers who process the personal data collected on our behalf and in accordance with our instructions. These service providers mainly work to assist in anti-fraud analysis, payment intermediation, marketing campaign management, logistics, database enrichment, and cloud storage.

Judicial, police, or governmental authorities:

• We must provide personal data of Customers and/or Users in compliance with a court order, requests from administrative authorities, legal or regulatory obligations, as well as to collaborate with government authorities, usually in investigations involving illicit acts.

Storage and Security:

We store your data securely in data centers located in Brazil, as well as abroad. In the case of storage abroad, all applicable legal measures are adopted, in accordance with the General Data Protection Law and its future regulations, ensuring the protection and privacy of your personal data.

We adopt the best techniques to protect the personal data collected from unauthorized access, destruction, loss, alteration, communication, or any form of improper or unlawful treatment, including encryption mechanisms. However, no platform is completely secure. If you have any concerns or suspect that your data is at risk, please contact us through our customer service channels, and we will be happy to assist you promptly.

Your personal data will be kept for the entire period that you are an active KeeyPC customer. After this period, we may store your personal data for an additional period for audit purposes, to enable compliance with legal or regulatory obligations.

We will retain your data for the necessary period, respecting the deadlines established in the applicable legislation.

Cookies and Monitoring Technologies:

We may use certain monitoring technologies to collect information about the activities carried out on our platform automatically. The information collected through such technologies is used to perform application performance metrics, identify usage problems, capture user behavior in general, and collect content impression data. Below are some of the technologies that may be present at KeeyPC:

Cookies: A cookie is a small file added to the user’s device to provide a personalized experience of accessing the platform. Cookies help analyze internet traffic and let us know when the user visited a specific site. A cookie does not provide access to a computer or reveal information beyond the data the user chooses to share with us.

Pixels: Pixels are parts of the JavaScript code added in our applications, websites, or in the body of an email, with the purpose of tracking and collecting information about user activities. This allows identification of user access patterns, navigation, interests, and product purchase data, optimizing the targeting of content.

Web Beacon: A web beacon is a technique that allows mapping who is visiting a specific web page, identifying user behavior with different sites or web servers.

Analytics tools: These tools can collect information about how users visit our store, which pages they visit, and when they visit those pages, among other things.

International Data Transfer:

Some of your personal data may be transferred to other countries, for example, when we use cloud computing services for data processing or storage, located outside of Brazil. However, do not worry. KeeyPC also observes all the requirements established in the current legislation in these situations and adopts market best practices to ensure the protection and privacy of your personal data.

Your Rights as the Data Subject:

Transparency about the treatment of your personal data is a priority for KeeyPC. In addition to the information provided in this Privacy Policy, you can also exercise the rights provided for in the General Data Protection Law, including:

• Confirmation of the existence of personal data processing.
• Access to personal data.
• Revocation of consent.
• Correction of incomplete, inaccurate, or outdated personal data.
• Elimination of personal data processed with consent or unnecessary, excessive, or when understanding that some point of the LGPD has not been met.
• Information about the hypotheses and with which companies, partners, and other institutions we may share or receive personal data related to you.
• Information about the possibility of not providing consent and the consequences of refusal when applicable.

All requests will be processed for free and will be subject to a prior assessment of your identity and the feasibility of meeting the request, to comply with any obligations that prevent the complete fulfillment of the requests of data subjects.

Retention and Deletion of Your Personal Data:

We will treat your personal data with high levels of protection and guarantee your privacy throughout the period that you are our customer, navigating our platform, and using our services or potential customer with whom we share our product and service offerings.

When applicable, and even if you choose to delete your personal data from our database, KeeyPC may retain some or all of your personal data for additional periods to comply with legal or regulatory obligations, for the regular exercise of KeeyPC’s rights, any legal actions, various audit purposes, or other periods defined and grounded by legal bases justifying the retention of this data.

The user can request the display, correction, confirmation of processing existence, limitation, opposition/revocation of consent, or deletion of their Personal Data through direct contact via email: [email protected].

If the user withdraws their consent for purposes essential to the regular operation of our platforms, these may become unavailable for the user. In this case, the User declares themselves fully aware that KeeyPC may terminate, limit, and/or change the provision of products and/or the execution of any services, without any liability.

If the user notices that any of the information obtained is incorrect or incomplete, they should inform KeeyPC through the aforementioned email for immediate correction.

Anti-Fraud:

We care a lot about your well-being and your experience on our platform. For this reason, we have created an order management department, in which we conduct real-time verification for each order, checking some terms to identify frauds, along with our anti-fraud system.

If your account is identified as a possible fraud, it may be blocked and removed from our platform, deleting all personal and order data. If your account is verified and identified as a possible fraud, please contact our support through the available channels.

Change of This Privacy Policy:

We are constantly seeking to improve our customers’ experience. Therefore, our practices for the treatment of personal data may undergo changes with the inclusion of new features and services. We value transparency in how we treat your personal data.

Whenever any relevant condition of this Privacy Policy is changed, these changes will be valid, effective, and binding after the new version is published on our website. These changes will be communicated through one of the channels provided by you during your registration (email, SMS, WhatsApp, and others).

Contact Us:

Whenever you have any doubts about this Privacy Policy, even after reading it, or need to interact with us regarding matters involving your personal data, you can do so:

• Through our customer service channels available in the Customer Service, requesting options regarding the privacy of your personal data, whenever available; or
• Through the email of the Data Protection Officer: [email protected].

We recommend that you check the updated version of this Privacy Policy whenever you browse our virtual store. We are always available to clarify your doubts and put you in control of your personal data. Count on us to keep you informed!”