PRIVACY POLICY

Last updated: March 31, 2026

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use Our Website and Our CRM Platform ("Service"). It also explains Your privacy rights and how the law protects You.

By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

1. INTERPRETATION AND DEFINITIONS

For the purposes of this Privacy Policy:

• Company (referred to as either "the Company", "We", "Us" or "Our") refers to Konecty Informática Ltda, Rua Dr. Jorge Fayet, 757 - Chácara das Pedras - Porto Alegre - RS, Brazil.
• Customer (B2B) refers to the legal entity (e.g., real estate agencies) that subscribes to Our Platform to manage their own clients, marketing, and sales processes.
• Data Controller refers to the entity that determines the purposes and means of processing Personal Data.
• Data Processor refers to the entity that processes Personal Data on behalf of the Controller.
• Data Subject (or End-User) refers to any identified or identifiable natural person, including the Customer's clients who interact with the Customer via messaging apps (e.g., WhatsApp) managed through Our Platform.
• Platform or Service refers to the Konecty CRM web application, including its Artificial Intelligence automations and messaging integrations.

2. OUR ROLE IN DATA PROCESSING

To ensure full compliance with global data protection laws (such as LGPD, GDPR, and CCPA), Konecty acts in two distinct capacities depending on the context of the data interaction:

• Konecty as a Data Controller: When You visit Our Website, request a demo, or create an Account to become a direct Customer, We act as the Data Controller of Your direct personal information (e.g., Your name, business email, and browsing cookies).
• Konecty as a Data Processor: When a Customer uses Our Platform to communicate with their End-Users (e.g., capturing leads, managing real estate conversations via WhatsApp), the Customer is the Data Controller. Konecty acts strictly as the Data Processor, providing the technological infrastructure. It is the sole responsibility of the Customer to obtain the necessary legal consent (opt-in) from their End-Users.

3. DATA ACCESS AND ARTIFICIAL INTELLIGENCE (SCENARIOS OF USE)

We prioritize confidentiality and transparency in how data flowing through Our Platform is accessed and utilized. We operate under two main scenarios regarding Platform Data:

Scenario 1: Restricted Customer Access (Internal Use)

All conversations, leads, and personal data generated between a Customer and their End-Users are strictly compartmentalized. This data is exclusively accessible by the respective Customer and their authorized personnel (e.g., real estate brokers and managers) for their own internal processes, marketing, and profiling. Konecty does not share, cross-reference, or divide personal data or quantitative performance metrics between different Customer companies.

Scenario 2: Artificial Intelligence Training (Anonymized Use)

To deliver a state-of-the-art CRM experience, Konecty utilizes Artificial Intelligence (AI) to automate processes and improve Our Service. We reserve the right to process data flowing through Our Platform to train, enhance, and develop Our proprietary Artificial Intelligence models.

• Strict Anonymization Guarantee: To protect privacy, all data used for Konecty's internal AI training purposes is strictly and irreversibly anonymized. All personally identifiable information (such as names, phone numbers, financial values, and document numbers) is systematically removed or masked before processing. Under applicable data protection laws, anonymized data is no longer considered Personal Data.
• Opt-out: Customers may opt out of having their anonymized data included in Our AI training models exclusively through custom enterprise agreements (Service Addendums).

4. COLLECTING AND USING YOUR PERSONAL DATA

Types of Data Collected:

• Personal Data (Directly from Customers): Email address, first and last name, phone number, company details, and billing information.
• Platform Data (Processed on behalf of Customers): Messages, files, and communication logs originating from messaging integrations (such as WhatsApp).
• Usage Data: Automatically collected data including Your Device's IP address, browser type, pages visited, time spent, and diagnostic data.

Tracking Technologies and Cookies: We use Cookies and similar tracking technologies to track activity and store certain information. We use both Session and Persistent Cookies essential for website functionality, security authentication, and user preferences.

5. THIRD PARTIES AND SUB-PROCESSORS

We engage trusted third-party Service Providers (Sub-processors) to facilitate Our Service. Approved Sub-processors include:

• Cloud Infrastructure: Google Cloud, DigitalOcean, AWS, MongoDB, Cloudflare, Backblaze.
• Messaging APIs: Meta Platforms (WhatsApp).
• Artificial Intelligence and LLMs: OpenAI, Google (Gemini), OpenRouter, and similar providers.

6. RETENTION OF YOUR PERSONAL DATA

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy to comply with our legal obligations and resolve disputes.

Data processed on behalf of Our Customers (such as CRM logs and WhatsApp conversations) is retained according to the Customer's settings and statutory limitations (e.g., 5 years for consumer protection defense).

7. SECURITY OF YOUR PERSONAL DATA

We employ industry-standard encryption, controlled access environments, and secure software development practices to protect against unauthorized access. While We strive to use commercially acceptable means to protect Your Personal Data, no method of transmission over the Internet is 100% secure.

8. YOUR DATA PRIVACY RIGHTS AND ERASURE

Depending on Your jurisdiction, You have the right to access, correct, port, or request the deletion of Your Personal Data.

• If You are a direct Customer or Website Visitor: You may submit a request to erase or access Your data by contacting us at [email protected]. We will process your request promptly. We may ask for basic information to verify your identity, but we will not request excessive sensitive documentation unless strictly required by law.
• If You are an End-User of a Konecty Customer: Because Konecty is merely the Data Processor for the communications You have with Our Customers, You must direct any requests to access, correct, or delete Your Personal Data directly to the Customer (e.g., the real estate agency) You interacted with.

9. CHANGES TO THIS PRIVACY POLICY

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top.

10. CONTACT US

If you have any questions about this Privacy Policy or wish to exercise your data rights, You can contact us:

• By email: [email protected]
• By visiting our website: https://konecty.com/privacy-policy