Privacy Policy

Effective Date: April 25th, 2023

This Privacy Policy (“Policy”) is meant to provide transparency to the processing of your personal data carried out by Kodo Limited, a company incorporated under the laws of Bahamas, with certificate of incorporation number 209391 B, with registered office at Shirley and Charlotte Streets, Bahamas Financial Center, 3rd floor, Nassau, registered in CNPJ under no. 47.579.473/0001-59 (“KODO”, “we” or “our”) as well as by third parties acting on KODO’s behalf and aims to describe the measures taken to ensure compliance with the applicable legislation. The terms and concepts used here are aligned with the GDPR.

KODO respects your privacy and is committed to protecting you personally identifiable information.

By using our website and/or providing your personal data, we consider that you have understood the terms of this Policy, as of the Site Terms and Conditions (“T&Cs”).

Types of personal data KODO collects

Below you can view each of the situations where KODO uses the personal data it collects.

• Analyze how you interact with the website to correct potential errors;
• Develop new features and provide better security;
• Contact and correspond with you and to respond to your inquiries;
• Process the transactions you perform on our website;

Some of your personal data may be provided to third parties when justified by legitimate business purposes and/or regulatory obligations.

In this context, KODO commits itself to solely engage with third parties whose security measures and best practices follow the ones upheld by this Policy, and to restrict data transfers to the minimum necessary to fulfill its purposes.

Retention of data

We store personal data exclusively when justified by a legal basis and specific purpose and keep your personal information for as long as it is required in order to fulfill the relevant purposes described in this Policy.

As a rule, we store personal data to ensure contract enforcements, to comply with legal and regulatory obligations and to meet our legitimate interests, always respecting the rights of the data holder and in accordance with applicable local laws.

Security of personal data

We have taken technical, administrative and legal measures to ensure that the data processing carried out by us is always in compliance with the applicable law and with high standards of information security.

We take the necessary precautions to prevent incidents related to the processing of personal data, including leaks, unauthorized access, loss, alteration, or any other form of irregular processing. In the event of incidents related to personal data, we will take all measures to mitigate the consequences in accordance with the provisions of the applicable legislation.

Kodo is committed to put its best efforts to keep your personal data secure, despite the fact that it is not feasible, technically, to ensure its inviolability in the event of any external attacks and/or system failures.

International transfers of personal data

Your data may be shared, transferred to and maintained on servers located outside of your state, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. KODO can also share your personal data with third parties who have their servers allocated in other countries, in cases of cloud storage, for example.

In such cases, we will take all the reasonable measures to ensure that your personal data is treated securely and will require the partner in the country of destination to offer adequate privacy rights and protection to data subjects and/or that there are adequate safeguards to maintain compliance with the provisions in this Policy.

Your consent to this Policy followed by your submission of such information represents your agreement to that transfer.

Collection and use of Cookies

Cookies are small text files that are downloaded to the browser of a computer, smartphone or other equivalent used to visit a website. After your visit, a cookie file is stored in the web browser and allows KODO to recognize you and make your next visit easier, making our website more useful to you. Essentially, cookies are the user's id card for KODO servers.

That is, the main object of cookies is to allow your browser to "remember" your actions and/or preferences over time, making it possible to provide our services more quickly and efficiently, eliminating the need to repeatedly request the same information.

KODO collects through cookies only the metadata of your browsing history on our website. In this way, data such as your username is recorded to facilitate your access on an upcoming visit to the site, for example.

All browsers (browsers like Google Chrome, Internet Explore, FireFox, etc. ) allow the user to manage cookies. When visiting/accessing a website, you can either accept, refuse or delete cookies, including by selecting the appropriate settings in your browser. You can set cookies in the "options" or "preferences"menu of your browser.

Removing or rejecting cookies from your browser may affect some features of our platform.

Your data protection rights

KODO understands that it is your right to receive transparent and complete information about the processing of your personal data. Thus, whenever formally requested and, within legal limits, KODO will use its best efforts to fulfill your requests.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you;
• The right of rectification, if the information firstly submitted is inaccurate or incomplete.
• The right to object to our processing of your personal data;
• The right to request the restriction of processing your personal data;
• The right to data portability, which means that you have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format;
• The right to withdraw consent at any time where Kodo relied on your consent to process your personal data;
• The right to complain to a Data Protection Authority about our collection and use of your personal data.

We emphasize that some personal data collected must be kept in our files for a legally determined minimum period, even if you request its deletion.

Any rights-related requests must be sent to the following registered email address: help@kodoassets.com.

Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time, at our discretion. Any changes or updates of this Policy will be informed through our website and can be communicated to you by e-mail, if you have registered in our mailing.

If you need further clarification or in case of any questions about this Policy, we will be happy to serve you, through the following email: help@kodoassets.com.