Privacy Policy

01Introduction

The purpose of this Policy is to explain how your personal data is processed by AKEN's website and to safeguard the privacy of the Platform's users. Therefore, the intent of this Policy is to inform how users' personal data is processed by AKEN, ensuring respect for users' fundamental rights and freedoms under the law, especially the Brazilian General Data Protection Law (LGPD, Law No. 13,709/2018).

We adopt this Privacy Policy, which determines how we process the information collected by the aken.com.br website and also explains why we need to collect personal data about you. For this reason, it is very important that you carefully read this document and its eventual updates.

02Definitions

To begin with, it is important to present some terms that will be used throughout our Policy:

• "LGPD":the Brazilian General Data Protection Law (Law No. 13,709/2018), which governs the processing of personal data, including by digital means, by a natural person or by a legal entity under public or private law, with the purpose of protecting the fundamental rights of freedom and privacy and the free development of the personality of the natural person.
• "Personal Data":any information related to an identified or identifiable natural person. For example, information that identifies a natural person, such as name, ID number, taxpayer number, address and phone; or that makes it possible to identify that person in some cases, such as geolocation, IP address etc.
• "Sensitive Personal Data":personal data on racial or ethnic origin, religious belief, political opinion, membership of a union or of a religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data, when linked to a natural person. In this Policy, Personal Data encompasses personal data and sensitive personal data.
• "Data Subject":the natural person to whom the Personal Data subject to Processing refers.
• "Processing":any operation carried out with Personal Data, such as those referring to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
• "IP":abbreviation of Internet Protocol. It is an alphanumeric set that identifies the user's connection on the Internet.
• "Cookies":files sent by the server to users' computers or mobile phones, in order to identify the device and obtain access data, such as pages browsed or links accessed, thus allowing navigation on the platform to be personalized according to your profile.
• "Cloud Computing":a service virtualization technology built from the interconnection of more than one server through a common information network (for example, the Internet), aiming to reduce costs and increase the availability of the supported services.
• "ANPD":the Brazilian National Data Protection Authority, as defined in the LGPD.

03About AKEN

AKEN was founded in 2004 and in 2013 started its partnership with SolarWinds, and today holds 85% of the SolarWinds market in Brazil, being the main reseller of the software. Today we operate with licensing (specialized consulting in technology licensing).

04Collection of Personal Data

We take care of your personal data and assume the responsibility of ensuring the confidentiality and security of your personal information.

Therefore, we explain here the origin of the personal data we use and have access to:

• When you visit the aken.com.br website, we automatically collect certain information about your device, including information about your browser, IP address, time zone and some of the cookies installed on your device.
• In addition, when you browse the website, we collect information about the individual pages or products or services you view, about which websites or search terms referred you to our website, and about how you interact with the website.

We refer to this automatically collected information as "Device Information". In addition, we may collect personal data that you provide (including, but not limited to: first name, last name, address, payment information etc.) during the registration process, in order to fulfill the agreement.

05Purpose of Processing

Our highest priority is the security of users' personal data, therefore we may process only minimal data, only for as long as it is absolutely necessary for the maintenance of the website. Automatically collected information is used to identify potential cases of abuse and to establish statistical data on the use of the website.

You may visit the website without telling us who you are or revealing any information that could be used by another person to identify you individually. If, despite this, you wish to use any of the website's features, receive our newsletter or provide other details by filling in and submitting forms, you may provide personal data to us, such as your e-mail, first name, last name, city of residence, organization and phone number.

You may choose not to provide personal data to us, but in that case you may not be able to use some of the website's features. For example, you will not be able to receive our newsletter or contact us directly through our website. Users who are unsure about which personal information is mandatory are invited to contact us at [email protected].

06Storage of Personal Data

We ensure that the information you provide is kept on servers and computers stored in secure and controlled environments, protected from unauthorized access, use and disclosure. We maintain reasonable administrative, technical and physical security measures, in order to protect the personal data under our custody from unauthorized access, use, modification and disclosure. Nevertheless, no data transmission over the Internet or by wireless systems can be guaranteed.

AKEN is only liable for any damages and/or losses arising from unauthorized access caused by failures, viruses or any other techniques of intrusion into AKEN's database upon exclusive and proven fault.

Your personal data, collected by AKEN, may be stored on AKEN's own server or on servers of third parties contracted for this purpose, and may also be stored in the cloud (cloud computing) and/or other forms of storage that may arise in the future, always seeking the improvement and enhancement of AKEN's activities and the security of your personal data.

AKEN's servers are located in Brazil, so that when data is stored on servers located abroad, AKEN undertakes to comply with all international personal data transfer requirements provided for in the General Data Protection Law and other applicable legislation, adopting the appropriate transfer mechanisms, as applicable.

07Sharing of Personal Data

AKEN may share your personal data with:

• Other companies of the same economic group or affiliates of AKEN;
• Public entities, bodies or authorities, under the applicable law;
• Companies authorized by AKEN to process your personal data as necessary to carry out the activities related to the operation of the websites and/or other contracted services;
• Business partners, for marketing purposes.

In the event of corporate changes or transactions involving AKEN, if the sharing of data proves necessary for the regular continuity of the company's services, AKEN may also share your personal data.

Internally, your personal data will only be accessed by professionals duly authorized by AKEN, within legal limits and respecting the principles of proportionality, necessity and relevance, so that AKEN can achieve its objectives, in addition to the commitment to confidentiality and preservation of your privacy, under the terms of this Policy.

08Transfer of Personal Data to Other Countries

If personal data is transferred to another country during processing by AKEN, we will adopt the measures required by law to ensure that the personal data remains protected, and that such transfer is carried out in accordance with one of the transfer mechanisms provided for in the LGPD and in accordance with regulations and guidelines to be defined by the Brazilian National Data Protection Authority ("ANPD").

09End of Personal Data Processing

In accordance with applicable law, AKEN will use personal data for as long as necessary to fulfill the purposes described in this Policy, or to comply with applicable legal requirements.

In any case, we adopt technical, administrative and operational measures to ensure the security of personal data while it is stored with us, considering the current state of the art, thus preventing any change in the availability, integrity and confidentiality of personal information.

10Third-Party Websites

This Privacy Policy does not cover third-party websites. We are not responsible for the privacy, information or other practices of any third parties or their websites, even if accessible via a link on our own website. The inclusion of a link on our website does not imply endorsement of that website by us or by the other companies of our economic group.

11Rights of Personal Data Subjects

You have rights and guarantees regarding your personal data under the LGPD. In certain circumstances, you may request from AKEN:

• Confirmation of and access to your personal data:you may request details and/or a copy of your personal data stored by AKEN;
• Change or correction of your personal data:you may request a change to the personal data we hold about you when you identify that it is incorrect and/or incomplete and/or outdated;
• Withdrawal and/or deletion of your consent (where applicable):you may withdraw the consent previously given to AKEN, under the terms of the LGPD. The withdrawal of your consent will make it impossible for you to use all the features of AKEN's websites.

If you wish to exercise these rights, please contact us at [email protected].

12Information Security

We use reasonable organizational, technical and administrative measures to protect information under our control and we strive to protect the Personal Data we keep in our records, considering the available state of the art. Once the data is received, we undertake to ensure its confidentiality, availability and integrity, preventing unauthorized access to or disclosure of your Personal Data, through physical, electronic and administrative procedures.

It is worth noting that no data transmission over the Internet or data storage system can be considered 100% secure. If you identify reasons to believe that your interaction with us is no longer secure (for example, signs that the security of any account you have with us has been compromised), please notify us immediately about the problem at [email protected].

13Legal Statement

We will disclose any information we collect, use or receive if such disclosure is requested in order to comply with subpoenas or similar judicial proceedings, and also when we consider, in good faith, that disclosure is necessary for the protection of our rights, for the protection of the safety of others, for fraud investigations or to respond to a government request.

14Changes to the Privacy Policy

This Policy may be changed at any time, according to our practices and in compliance with applicable law. We will give notice if this Policy undergoes any significant structural modification, however we recommend that you access it frequently, or whenever you have questions, to keep track of any updates. It is worth remembering that our Privacy Policy will be available on our website, Portal and Platforms.

15Contact Channels

If, after reading this Policy, you still have any questions or wish to submit any request regarding your personal data, please contact us at the e-mail address [email protected].