Last modified: August 18, 2021.


1. Introduction

1.1 This is Kunumi's Privacy Policy ("Privacy Policy" or "Policy"), which clearly sets out all the possibilities for processing personal data by Kunumi Serviços em Tecnologia da Informação SA, a limited liability company registered under the CNPJ in the 32.182.953/0001-04, headquartered in Belo Horizonte – Rua Rio Grande do Norte, 1435, room 708 – Savassi  (“Kunumi”), due to the Services offered by it, in compliance with the provisions of the General Law for the Protection of Personal Data (Law No. 13,709/2018 or “LGPD”).

1.2 Kunumi is a company that works to reframe complex challenges through the lens of artificial intelligence and emerging technologies. These activities are developed by Kunumi both from scientific research in partnerships with universities, and for the benefit of companies that aim to implement artificial intelligence solutions in their business models (“Customers”). Kunumi also provides courses for companies and their employees who want to learn more about artificial intelligence and its applications. Collectively, these activities are understood to be the services offered by Kunumi (“Services”)

1.3 This Policy describes what information Kunumi collects in its relationship with users of these Services (“you”): when you interact with Kunumi Contact Channels to contact the company via email and other means of communication , as a subscription to the Kunumi Newsletter (“Kunumi Contact Channels”). The processing of your personal data is also carried out in Kunumi's business relationships with (potential) Suppliers, Customers or Partners in the context of providing the Services.

1.4 Kunumi respects your privacy and recognizes how important it is for you to know and be confident about the use of your personal data. Therefore, it is recommended that you read this Policy carefully.

1.5 During the performance of most of its Services, Kunumi acts as the operator of personal data. In these cases, Kunumi carries out the processing of personal data as expressly instructed by the controller of such data (that is, the Partner), not being responsible for the privacy or security practices adopted by it. To understand how your personal data is handled by these Partners, it is recommended that you consult their respective Privacy Policies and Terms of Use.


2. Personal data collected

2.1 For purposes of this Policy and applicable laws, Kunumi considers any information that identifies you or allows you to be identified as personal data. Anonymized or aggregated data is not considered personal data.

2.2 All personal data collected by Kunumi is related to the Services offered and your interaction with the Channels of Contact with Kunumi, as well as to improve the Services provided and the Channels of Contact with Kunumi, your experience with Kunumi, the development of new Services that are of interest to you, and partnerships and associations that Kunumi may form in the future.

2.3 Due to the Services provided and the Contact Channels with Kunumi, after obtaining your consent (where necessary) and within the limits allowed by the LGPD, Kunumi may collect the following personal data of its ownership:

2.3.1 Identification and contact data: data such as first name, last name, and contact information (eg email address), among other information related to your interaction with Kunumi Contact Channels.

2.3.2 Professional data: data such as name, surname, contact information, professional activity, field of activity, position, company for which you work, to enable the performance of the Services provided by Kunumi.

2.3.3 Navigation related data: data collected while you use Kunumi Contact Channels, including through your browsing on Kunumi platforms, such as location data derived from your IP address or other means, geolocation and other real-time location information, technical data , such as the computers, phones and other devices through which you install or access Kunumi Contact Channels, the type of network connection (e.g. Wi-Fi, 3G, LTE) and provider, network and device performance, and browser type, operating system and application version used, where applicable; or even generated from any interaction between you and other users, or system and features of Kunumi, or other entities linked to it by contract or technical bond, through the Services offered.

2.3.4 Additional data: in the form and within the limits of the corresponding consent granted by you (where necessary), in accordance with the provisions of this Policy and to the extent permitted by the LGPD.



3.1 Kunumi collects your personal data in the following ways:

3.1.1 Information you share with Kunumi: in your interaction with Kunumi's Contact Channels, you provide various data, such as full name and e-mail address, through, for example, the “Get to know” and “Subscribe to our Newsletter” fields on the Kunumi website. Kunumi processes the personal data necessary to respond to your inquiries, queries or other requests.

3.1.2 Information that the company you work for provides to Kunumi or other companies of the same economic group: Kunumi may receive your personal data from one of its Customers or Suppliers, for whom you work or provide services to enable the Services provided by Kunumi.

3.1.3 When you access the Kunumi website: Through cookies and other similar technologies, data such as page views and devices and devices used for browsing are collected, as well as information regarding your use of certain features of the Services.

3.1.4 From companies belonging to the Kunumi economic group: or that are operated by Kunumi in accordance with their respective terms of use and privacy policies.

3.1.5 Your personal data may also be provided directly by Kunumi's client companies ("Partners"), for Kunumi to use them on behalf of Partners and within the limits established by them and by applicable law.


4. Purposes of processing personal data

4.1 Personal data collected by Kunumi during the use of the Services may be used for the following purposes:

4.1.1 Achieve Kunumi's mission in the offering the Services, which includes your registration and identification to the extent necessary and adequate for the provision of Kunumi Services, as well as for the feasibility of using the Contact Channels with Kunumi.

4.1.2 Allow the enrichment of the database through techniques of crossing, cleaning, integration and pre-processing of data. Kunumi carries out this data processing only when requested by the Partner, in accordance with the conditions detailed in its own Privacy Policy or Terms of Use.

4.1.3 Enable the elaboration of technical consultancy and development of artificial intelligence models aimed at several areas such as health, credit protection and financial products, at the request of the data controller and in accordance with the conditions detailed in its own Privacy Policy or Terms of Use.

4.1.4 Perform analysis and processing of Partner databases to find purchasing patterns and behavior, at the request of the data controller and in accordance with the conditions detailed in its own Privacy Policy or Terms of Use.

4.1.5 Get in touch with you, in cases where you have registered in the Channels of Contact with Kunumi, as well as to maintain professional contact with you.

4.1.6 Improve the commercial and promotional initiatives of Kunumi, to the extent permitted by applicable law, such as the LGPD, which includes sending you commercial communications and/or email marketing accomplishments, or other forms of marketing related to the Kunumi Services.

4.1.7 Allow sending of notices regarding Kunumi Services, as well as its internal policies, in order to allow you to explore all the features offered by Kunumi in the provision of its Services and in the use of the Channels of Contact with Kunumi.

4.1.8 Assist in verifying accounts and activities and provide security on and off the Kunumi Contact Channels and Services, investigating suspicious activity or violations of this Policy.

4.1.9 Generate statistical analysis regarding the use of the Contact Channels and the Services provided by Kunumi.

4.1.10 Share information with the 3rd to the extent necessary to enable the Channels of Contact with Kunumi and the provision of the Services, respecting the limits imposed by the applicable legislation.

4.1.11 Share the information within the scope of other platforms, products and services that are part of the economic group to which Kunumi belongs or will belong, in order to benefit you and other users and enable the Contact Channels and Services provided, in a coordinated manner with other companies.

4.1.12 Allow legal audit for the purpose of corporate transactions, such as the merger, acquisition or sale of all assets of Kunumi, its economic group, or part of each of them, and transfer the information to the new owner, if the ownership or control of all or a part of Kunumi or its assets is changed.

4.1.13 To comply legal and regulatory obligations, to respond, to the extent strictly necessary, to determinations of judicial, administrative or arbitration authorities (e.g. court order, search warrant or subpoena), if Kunumi understands, in good faith, that it is necessary to do so or so is required in law or by judicial, administrative or arbitration decision, or for the defense of Kunumi in proceedings before the aforementioned authorities.

4.1.14 other purposes, in the form and within the limits of the corresponding consent granted by you (when necessary), and to the extent permitted or required by applicable law, including the GDPR.


5. Sharing of collected personal data

5.1 In cases where it is necessary for the provision of the Services, within the limits allowed by the LGPD, Kunumi may share your personal data with third parties. This sharing will seek to achieve the following purposes:

5.1.1 Enable the offering or operating the Kunumi Services, including for the purpose of communicating with you, through the sharing of personal data with service providers and/or partners (eg companies that provide cloud storage services), always within the strict limits authorized by applicable law.

5.1.2 Allow, in cases where strictly necessary, legal audit for purposes of corporate transactions, such as a merger, acquisition or sale of all assets of Kunumi, its economic group, or part of each of them, and transfer the information to the new owner, if ownership or control of all or a part of Kunumi or your assets is changed. The provisions in this Privacy Policy will continue to apply to your personal data if they are transferred to the new owner.

5.1.3 Allow the performance of partnerships by Kunumi, through the sharing of personal data, insofar as they are necessary for the realization of these partnerships, always within the strict limits authorized by the applicable legislation.

5.1.4 Develop new products and offers that are of interest to you.

5.1.5 Respond, as strictly necessary, to requests from judicial, administrative or arbitration authorities (e.g. court order, search warrant or subpoena), if Kunumi understands, in good faith, that it is necessary to do so or is required by law or by judicial, administrative or arbitration decision, and permits compliance and the execution of legal and regulatory obligations, through requirements for sharing personal data with the competent authorities as strictly necessary.

5.1.6 other purposes, in the form and within the limits of the corresponding consent granted by you (where necessary), and to the extent permitted or required by applicable law.


6. Cookies and Similar Technologies

6.1 Technologies such as cookies, pixel tags, device identifiers or others and local storage (“Cookies and similar technologies”) are used to transmit, protect, understand and improve the Channels of Contact with Kunumi during your navigation.

6.1.1 Cookies are small files stored on your browser, mobile phone or other device. Pixel tags (also known as clear GIFs, web beacons or pixels) are small blocks of code on a web page that allow them to perform actions such as reading and storing cookies and transmitting information to Kunumi Partners. The resulting connection may include information such as a device's IP address, the time a person viewed the pixel, an identifier associated with the browser or device, and the type of browser in use.

6.1.2 Local storage is an industry standard technology that allows a website or application to store and retrieve data from a person's computer, mobile phone or other device. Some examples include devices or HTML5 local storage and caching.

6.2 These technologies may be used, among others, to enable Kunumi to present the content and offerings most relevant to you, improve the Services and your use of Contact Channels, and help keep these Services secure.

6.3 The specific names of Cookies and similar technologies used may vary as the Services are improved and updated, but they are generally restricted to the categories of use below:

Responsible for indicating that you are connected, so that we can provide you with the appropriate resources, as well as to understand how you use the Contact Channels with Kunumi.

Website security and integrity
Responsible for helping to keep Contact Channels secure by providing support or enabling security features.

Ads, ideas and measurement
Responsible for analyzing browsing behavior and serving ads, making them more relevant to you and analyzing Contact Channels and their use. For example, you can use a cookie to find out if someone to whom an ad has been served makes a purchase on the advertiser's website or installs the advertised app later. Likewise, partners may use cookies or other similar technologies to determine whether Kunumi has displayed one of your advertisements and how it has performed, or to inform you of how you interact with it.

Website features and services
Responsible for helping to provide you with products and services, for example when you have viewed or interacted with content on the Services, and to provide you with other social plug-ins, other experiences and personalized content or make suggestions.

Responsible for providing the best possible experience, for example, helping to route traffic between servers and realizing how fast Kunumi Contact Channels load for different people. Occasionally, information may be stored on your browser or device so that resources in use load and respond quickly.

Analysis and research
Responsible for understanding, improving and researching services, including when you access Kunumi Contact Channels or other websites and applications from your computer or mobile device. For example, we may use Cookies or similar technologies (including information from your device) to understand how you are using social plug-ins and improve them, and information about this analysis may be shared with Kunumi's partners.

6.4 It is possible that you manage preferences for Cookies and other similar technologies from the configuration of your browser, refusing or deleting some of them. However, this option may compromise the use of the Kunumi Contact Channels or prevent the functioning of certain features that integrate the Contact Channels.


7. Website Features and Services

7.1 Kunumi's Services and Contact Channels may contain links to products from partners and affiliated companies, which have their own terms and policies. However, this Policy is limited to the Services and Contact Channels offered by Kunumi itself.

7.2 Although Kunumi constantly seeks to establish relationships with trusted partners, Kunumi is not responsible for the personal data processing practices carried out exclusively by these third parties. For this reason, Kunumi recommends that you read the external terms and policies before providing any personal data while using the Services and Kunumi Contact Channels.


8. Storage and security of personal data

8.1 When processing your data, Kunumi will endeavor to store and keep it safe. For this reason, Kunumi undertakes to implement, on an ongoing basis, physical, technical and administrative information security measures in the treatment of your personal data. Thus, it seeks to protect your personal data against unauthorized access, accidental or unlawful situations of destruction, loss, alteration of communication or any form of inappropriate or illegal treatment.

8.1.1 Kunumi allows its personal data to be accessed by its employees and other third parties only to the extent necessary to carry out their activities, in accordance with express instructions and under a contractual obligation of secrecy and confidentiality of the personal data processed.

8.1.2 Kunumi's practices related to information security will be guided by applicable legislation, good market practices and Kunumi's internal policies related to the topic.

8.2 Kunumi will retain your personal data for the period necessary to achieve the purposes indicated in this Policy, unless a longer retention period is required or permitted by the LGPD and other applicable laws.


9. International transfer of personal data

9.1 Kunumi, as a company aligned with the most current practices and technologies, may carry out international transfers of your personal data, in order to enable the development of some of the activities indicated throughout this Policy (eg: data storage in cloud services with servers located abroad).

9.2 Kunumi will carry out international transfers of your data only on the basis of mechanisms permitted by applicable law, including the LGPD.

9.2.1 In this sense, Kunumi undertakes to ensure the protection of your personal data through practices such as the conclusion of appropriate contractual agreements, in order to ensure that its business partners have data protection and information security standards compatible with those of this Policy.


10. Your rights as the holder of personal data

10.1 Kunumi will adopt appropriate technical and organizational measures to fulfill its obligations in relation to your rights as a holder of personal data. In this sense, Kunumi undertakes to make the best possible use of your rights as provided for by law.

10.2 In most of its operations, Kunumi appears as the operator and acts on behalf of the personal data controller (ie the Partner) in accordance with its instructions and interest. In such cases, Kunumi undertakes to collaborate with Partners in the realization of the rights of the holders of personal data, when requested to do so, within the limits of its involvement in the relevant personal data processing activity, and in line with the LGPD.

10.3 In cases where it acts as a controller, as indicated in this document, Kunumi will be responsible for guaranteeing the rights of the holders. Such rights are listed below, which are:

10.3.1 Confirmation: right to be informed about the existence of treatment by Kunumi.

10.3.2 Access: right to request access to personal data processed by Kunumi.

10.3.3 Correction: right to request the alteration of personal data processed by Kunumi whenever they are incomplete, inaccurate or out of date.

10.3.4 Restriction: right to object to the treatment or right to request the anonymization, blocking or deletion of unnecessary, excessive or data processed by Kunumi in violation of the legislation for the protection of personal data.

10.3.5 Portability: right to request the transmission of data processed by Kunumi to another service provider.

10.3.6 Elimination: right to request the deletion of personal data processed by Kunumi with your consent.

10.3.7 Information: right to be informed about the public and private entities with which Kunumi has shared data, about the possibility of not providing consent and about the consequences of this refusal.

10.3.8 Revocation of Consent: right to revoke consent, when the treatment depends on your consent, at any time, through express manifestation, by free and facilitated procedure. Revocation of your consent does not affect the legality of treatments carried out up to the time of revocation.

10.3.9 Review of automated decisions: possibility of reviewing decisions taken by Kunumi based on automated processing of personal data that affect your interests.

10.4 If you are interested in exercising any of the rights listed above, for activities in which Kunumi acts as a parent, you should contact Kunumi using the contact information indicated in the “General provisions” section below.

10.5 Furthermore, if you are interested in ceasing to receive messages from Kunumi, you can unlink from these messages at any time, by unsubscribing, which can be done using the opt-out link within the message sent.

10.6 In relation to the request for the deletion of your personal data, for activities in which Kunumi acts as controller, Kunumi will comply with requests for the deletion of personal data upon your request or in the face of legal obligations. In this case, this data will be definitively deleted, except for the cases of mandatory record keeping and maintenance allowed by applicable legislation, especially the LGPD.


11. General provisions

11.1 This Privacy Policy consists of the valid and effective version of the information about the processing of your personal data by Kunumi. This version is responsible for governing all relationships between you and Kunumi, except when you use services that have their own Privacy Policies, respecting acquired rights, perfect legal acts and res judicata.

11.1.1 The current version of the Privacy Policy will always be the most recent. To identify the current version date, you should check the “Last Modified” section at the top of this document.

11.2 Kunumi reserves the right to periodically update and modify any of its legal documents, including this Privacy Policy, in accordance with its business demands and internal regulations.

11.2.1 Any modification to this Policy that impacts the consent previously provided (where necessary) or imposes a financial burden on you will be communicated by Kunumi in advance. However, any changes made for legal reasons or due to new functionality of a Service will be effective immediately.

11.2.2 Kunumi is constantly looking for improvement to offer you the best possible experience when using the Services and Contact Channels. However, the Services and Contact Channels are provided as-is, so that Kunumi may freely implement changes, alterations, additions, deletions and any other forms of modification to the Services and Contact Channels.

11.2.3 You may stop using the Services and Contact Channels with Kunumi at any time. Likewise, Kunumi may also stop providing the Services and stop making the Contact Channels available to you at any time, as well as adding or creating new boundaries.

11.2.4 If you do not agree to any change to this Policy, you must discontinue using the Services and the Kunumi Contact Channels. Otherwise, the subsequent use of the Services and Contact Channels will result in your acceptance of the new version of the Policy.

11.3 Kunumi may make additional information available to you about its personal data processing practices in connection with certain Services and Contact Channels. This information may complement or clarify Kunumi's privacy practices or provide you with additional choices about how Kunumi handles personal data. In any case, Kunumi undertakes to follow the legal and regulatory obligations applicable to the processing of personal data and to its sector of activity.

11.4 The clauses of this Privacy Policy will remain in force in any form of termination, occurred for any reason, in order to continue to produce effects on the parties as long as there are subsequent legal relationships.

11.5 If you want to exercise any of the rights provided for in this Privacy Policy, or have any questions about this document and the practices described therein, you must contact Kunumi, via email