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Detection Privacy Policy Brazil K9

This Privacy Policy aims to demonstrate DETECCION BRAZIL K9's

commitment to the privacy and protection of the Personal Data it collects

from You, establishing the rules on the collection, registration, storage, use,

sharing, enrichment and elimination of your data collected, within the

scope of DBK9 's services and functionalities in accordance with current

laws, with transparency and clarity for you and the market in general.

As a condition for accessing and using the exclusive features of the

Platform, you declare that you have read this Privacy Policy completely

and carefully, being fully aware, thus granting your free and express

agreement with the terms stipulated herein, authorizing the obtaining of

the data and information mentioned here, as well as their use for the

purposes specified below. If you do not comply with these Guidelines, you

must discontinue access.

1. COLLECTION AND USE OF PERSONAL DATA AND ACTIVITY

RECORDING

1.1. Collection of personal data. The data is collected based on your

voluntary adherence to the use of the Platform, in addition to data

collected automatically, and includes:

DATA TYPES

PERSONAL DATA

PURPOSES

REGISTRATION

Identify and

authenticate you.

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Name; CPF/CNPJ

number; email ; billing

address.

Serve you! Comply with

obligations arising from

the use of the Platform’s

services.

To create a consumer

profile and carry out

advertising for

Deteccion’s offers and

services Brazil K9,

whenever possible,

anonymously .

Protect you! Carry out

fraud prevention, credit

protection and

associated risks,

compliance with legal

and regulatory

obligations and contract

execution.

DIGITAL

IDENTIFICATION

IP Address and Source

Logical Port; records of

interactions with the

Platform; screens

accessed; device

(operating system

version; geolocation .

Comply with legal

obligations! Comply with

the obligation

established by the Marco

Civil da Internet - Law no.

12,965/2014

established by the Marco

Civil da Internet - Law no.

12,965/2014

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Protect you! Carry out

fraud prevention, credit

protection and

associated risks,

compliance with legal

and regulatory

obligations and contract

execution.

1.2 Data sharing hypotheses. Collected Data and recorded activities may

be shared:

1. With competent judicial, administrative or governmental authorities,

whenever there is a legal determination, request, requisition or court

order;

2. Automatically, in the case of corporate movements, such as

mergers, acquisitions and incorporations;

3. With partner companies and authorized suppliers to meet the

purposes stated in this Policy, such as photography service

providers, extracurricular activities, transportation; It is

4. With companies from the Detection Group Brazil K9, always in

compliance with the security and Data protection guidelines and

to meet the purposes of this Policy.

1.2.1. In these cases, Detection Brazil K9 will share the minimum amount

of information necessary to achieve its purpose.

1.3. Subcontracting. The Detection Brazil K9 may subcontract the data

processing and storage service (Data Operator), so that you ARE AWARE

of the access and processing of Personal Data by third parties, service

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providers, whose purpose is to ensure the efficiency of services. to be

provided.

1.3.1. The Detection Brazil K9 undertakes to subcontract data

processing and storage services only to companies with the

respective specialty, guaranteeing all the rights of the Data Holder

and imposing rules and responsibilities on the subcontracted

Operator.

1.4. Data Security. The Detection Brazil K9 will make its best efforts to

protect information, applying the administrative and technical protection

measures necessary and available at the time, demanding from its

suppliers the same acceptable level of Information Security, based on

best market practices, based on clauses contractual.

1.5. Storage servers. The collected data will be stored on Deteccion 's own

servers Brazil K9 located in Brazil, as well as in an environment using

resources or servers in the cloud ( cloud computing ), which entails, in the

latter case, transfer or processing of data outside Brazil, complying with

provisions on international data transfer in accordance with article 33 of

the General Data Protection Law or other applicable standards.

1.6. Data veracity. The Detection Brazil K9 is not responsible for the

accuracy, veracity or lack thereof of the information provided by you or

for its outdatedness, or for the documents sent, and you are responsible

for providing it accurately and/or updating it.

1.6.1. The Detection Brazil K9 is not obliged to process or treat any of

your data if there is reason to believe that such processing or

treatment could result in any violation of any applicable law by the

companies or that the Platform is being used, under the sole

discretion of Deteccion Brazil K9, for any illegal, illicit or contrary to

morality purposes.

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1.6.2. Technologies used. The Detection Brazil K9 may make use of

technologies such as cookies, and it is up to you to configure your

internet browser if you wish to block them. In this case, some

Platform functionalities may be limited.

1.6.3. All technologies used will always comply with current

legislation and the terms of this Policy.

1.7. Third party links . It is important to highlight that, once on the Platform,

you may be led, between link, to portals or other platforms, which may

collect your information and have their own Privacy Policy, and it is up to

you to read them or reject them.

1.8. Consent changes. You may change your consent grants, grant new

permissions or request the revocation of your consent for current

permissions through Deteccion 's Service Channels Brazil K9, being warned

of the consequences that withdrawing consent may cause.

1.9. Data base. The database formed through data collection is the

property and responsibility of Deteccion Brazil K9, and its use, access and

sharing, when necessary, will be within the limits and purposes described

in this Policy.

1.10. Access to the database. Access to processed data is restricted only

to professionals duly authorized by Deteccion Brazil K9, and its use, access

and sharing, when necessary, will be in accordance with the purposes

described in this Policy.

2. DATA STORAGE AND RECORDS

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2.1. Data storage. The Personal Data collected and activity records are

stored in a secure and controlled environment for the period required by

law, considering:

PERSONAL

DATA

STORAGE PERIOD

LEGAL BASIS

Registration

data

During the period in

which they are relevant

to achieving the

purposes listed in this

instrument

Art. 7 of the LGPD and Art.

6 of the GDPR.

(Compliance with

contract between the

parties).

Digital

identification

data

6 months

Art. 15, Civil Rights

Framework for the

Internet

Other data

As long as the

relationship lasts and

there is no request for

deletion or revocation

of consent

Art. 9, Section II of the

General Personal Data

Protection Law

2.2. Data deletion. The data may be deleted before this period, if you

request. However, it may happen that the data needs to be kept for a

longer period, in accordance with article 16 of the General Law on the

Protection of Personal Data, to comply with a legal or regulatory

obligation, compliance with the contract, study by a research body

(ensuring, when possible, the anonymization of Personal Data), transfer to

a third party (respecting the data processing requirements set out in the

same law). After the deadline and legal necessity, they will be deleted

using safe disposal methods, or used anonymously for statistical purposes.

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3. RIGHTS OF THE PERSONAL DATA HOLDER

3.1. Data display and rectification. You can request the display or

rectification of your Personal Data through the Service Channels.

3.2. Limitation, opposition and deletion of data. Through the Service

Channels, it will also be possible to:

• request limitation and anonymization of the use of Personal Data;

• express your opposition to the use of Personal Data;

• request the deletion of your Personal Data, as long as the minimum

legal period related to data storage has elapsed; or

• claim data portability to another service provider in the same field,

upon express request, in accordance with the regulations of the

national authority.

3.2.1. If you withdraw your consent for purposes that are fundamental

to the regular functioning of the Platform, the services and

functionalities may become unavailable to you.

4. HOW TO EXERCISE YOUR RIGHT AS A DATA SUBJECT

4.1. Your rights as holder of personal data may be exercised directly by

you, through the management of registration information, while another

party will depend on sending a request on email:

barbosapedrottiadv@gmail.com for subsequent evaluation and

adoption of the necessary measures.

4.2. The User is aware that any request to delete essential information for

managing their registration with Deteccion Brazil K9 will result in the

termination of your contractual relationship, with the consequent

cancellation of the services then provided.

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4.3. The Detection Brazil K9 will make all reasonable efforts to respond to

requests made by Users in the shortest possible time. However, justifiable

factors, such as the complexity of the requested action, may delay or

prevent its rapid response, being certain that, in the event of delay, the

due reasons will be provided.

4.4. Finally, the User must be aware that their request may be legally

rejected, whether for formal reasons (such as their inability to prove their

identity) or legal reasons (such as the request for deletion of data whose

maintenance is a free exercise of rights by Detection Brazil K9 , given that,

in the event of it being impossible to meet these requests, Deteccion Brazil

K9 will present reasonable justifications.

5. GENERAL PROVISIONS

5.1. Data Officer. For all data processing purposes, as provided in

articles 5, item VIII and 41, §1 of the General Personal Data Protection Law,

declares Deteccion Brazil K9 has a data handler and can be contacted

through the Service Channels available on the website .

5.2. Update of Terms. The Detection Brazil K9 reserves the right to change

the content of this Privacy Policy at any time, according to the purpose or

need, such as for adequacy and legal compliance with a provision of law

or standard that has equivalent legal force, and it is your responsibility to

verify it. whenever you access the Platform.

5.2.1. In the event of updates to this document that require new

collection of consent, Deteccion Brazil K9 will notify you using the

contact details you provided.

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5.3. Service channels. If you have any questions regarding the provisions

contained in this Privacy Policy, you may contact Deteccion Brazil K9 on

email: legaldepartment@dbk9.com.br

5.4. Nullity. If any provision of this Privacy Policy is considered illegal or

illegitimate by the authority of the location in which you reside or your

internet connection, the other conditions will remain in full force and

effect.

5.5. Communication. You acknowledge that all communication carried

out by email (to the addresses provided in your registration), SMS, instant

communication applications or any other digital and virtual form are also

valid as documentary evidence, being effective and sufficient for the

disclosure of any matter that refers to the services provided by Deteccion

Brazil K9, as well as the conditions of its provision or any other matter

addressed therein, except for the expressly different provisions set out in

this Privacy Policy.

6. APPLICABLE LAW AND JURISDICTION

6.1. Applicable law and forum. This Privacy Policy will be interpreted in

accordance with Brazilian legislation, in the Portuguese language, with

the jurisdiction of the District of Curitiba being elected to resolve any

dispute or controversy involving this document, unless there is a specific

exception regarding personal, territorial or functional jurisdiction under the

applicable legislation.

7. DPO

7.1. The data controller – also called DPO (Data Protection Officer) – is

the person responsible to act as a communication channel between

Deteccion Brazil K9 and data subjects. The person appointed as DPO of

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Detection Brazil K9 is Jusconnect Soluções Empresariais LTDA, regularly

registered with the CNPJ under nº 45.660.624/0001-73, with electronic

8. COMPLIANCE WITH THE CONDUCT MANUAL

8.1. We reinforce our commitment to the highest standards of ethics and

compliance in all of our operations. Integrity is a core value that guides

our approach to protecting the privacy and confidentiality of our

customers' and users' data.

8.2. Our company adopts a "Manual of Ethical and Business Conduct,

Compliance and Anti-Corruption" as an integral part of our organizational

culture. The Ethical Conduct Manual establishes clear guidelines for the

appropriate and responsible conduct of our employees, partners and

other parties involved in our operations.

8.3. It is imperative that everyone involved with our company

understands and adheres to the Ethical Conduct Manual. This includes,

but is not limited to, our employees, contractors, suppliers and business

partners. The Ethical Conduct Manual defines expectations related to

integrity, business ethics, prevention of corruption and compliance with all

applicable laws and regulations.

8.4. In particular, we emphasize the importance of complying with

applicable data privacy laws and regulations, which are fundamental to

protecting the privacy of our customers and users. Our employees and

partners must be aware of their responsibilities with regards to data

security and privacy and must follow all relevant policies and procedures.

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8.5. The Ethical Conduct Handbook also highlights the need to report

any violations of ethics, compliance, or any privacy-related concerns. We

encourage everyone involved with our company to report any activity

that may be in violation of the Ethical Conduct Manual or our data

protection commitments.

8.6. When using our services or interacting with our company, you

acknowledge and agree with the importance of complying with the

Manual of Ethical and Business Conduct, Compliance and Anti-

Corruption. We are committed to promoting a culture of integrity and

protecting your privacy. For any questions, concerns, or reports of

violations, please contact us using the contact information provided in this

9. RECORDING AND STORAGE OF INSPECTION VIDEOS

9.1. Our company, dedicated to detecting explosives and narcotics

using sniffer dogs, values transparency and compliance with data privacy

regulations. As part of our services, it is necessary to record inspections

carried out on vessels to ensure the safety and integrity of our customers

and their operations.

9.2. As established in the LGPD (General Data Protection Law) in Brazil

and the GDPR (General Data Protection Regulation) in the European

Union, we are committed to ensuring that the collection, storage and

processing of personal data occurs lawfully, fair and transparent, based

on the following legal foundations:

1. Contract Execution (Article 7, item V of the LGPD and Article 6(1)(b)

of the GDPR): The collection and storage of videos and data related

to the inspection of vessels are necessary for the execution of

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contracts concluded with our customers. This includes allowing

vessel owners to track inspections carried out at their facilities.

2. Legitimate Interest (Article 7, item IX of the LGPD and Article 6(1)(f)

of the GDPR): We have a legitimate interest in maintaining visual

records of inspections to ensure the effectiveness of our services, as

well as to ensure security and integrity operations related to the

detection of explosives and narcotics.

3. Legal Obligation (Article 7, item II of the LGPD and Article 6(1)(c) of

the GDPR): In accordance with applicable laws and regulations, we

are obliged to keep records of inspections for safety, regulatory and

legal purposes.

9.3. Videos recorded during explosive and narcotics detection

inspections are securely stored in our system and are only accessible by

vessel owners or their authorized representatives. These videos will not be

shared with third parties without the explicit consent of the vessel owners,

except when required by law.

9.4. Videos recorded during inspections will be retained for the period

necessary to comply with our contractual, legal and regulatory

obligations. After the end of this period, the videos will be duly deleted.

9.5. According to data protection laws, you have the right to access,

correct or delete your personal data, including recorded videos (Article

18 of the LGPD and Article 17 of the GDPR). To exercise these rights or to

obtain more information about our privacy practices, please contact us

using the contact information provided in this privacy policy.

9.6. Thank you for choosing our services. We are committed to

protecting your privacy and complying with all legal data protection

obligations. If you have any questions or concerns regarding privacy or

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the use of videos during inspections, please do not hesitate to contact us.

Your safety and trust are of utmost importance to us.

10. GLOSSARY

10.1. For the purposes of this document, the following definitions and

descriptions should be considered for better understanding:

• Personal Data: information relating to an identified or identifiable

natural person;

• Cloud Computing : or cloud computing, is service virtualization

technology built from the interconnection of more than one server

through a common information network (example: internet), with

the aim of reducing costs and increasing availability of supported

services;

• Platform: designates the electronic address

legaldepartment@dbk9.com.br and its subdomains;

• Person in charge: person appointed by the controller and operator

to act as a communication channel between the controller, data

subjects and the National Data Protection Authority;

• Controller: natural or legal person, governed by public or private

law, who is responsible for decisions regarding the processing of

Personal Data;

• Operator: natural or legal person, governed by public or private

law, who processes Personal Data on behalf of the controller;

• National authority: Public Administration body responsible for

ensuring, implementing and monitoring compliance with the

General Data Protection Law throughout the national territory;

• Cookies : files sent by the Detection server Brazil K9 for your mobile

device or desktop , with the purpose of identifying the device and

obtaining access data, thus allowing you to personalize your

navigation on the Platform, according to your profile;

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• IP: abbreviation for Internet Protocol . It is an alphanumeric set that

identifies your device on the internet; It is

• You: natural or legal person who accesses and/or uses the

Platform’s functionalities.