Kobana
Data Protection

Privacy Policy

Kobana collects some Personal Data from Users. This document details how we collect, use, protect and share your data, in compliance with LGPD and GDPR.

Last updated: March 12, 2026

1. Data Owner and Controller

Kobana Tecnologia Ltda.

CNPJ: 05.813.794/0001-26

Calçada das Margaridas, 163, Sala 02

Centro Comercial Alphaville - Barueri, SP

CEP 06453-038

Owner contact email: lgpd@kobana.com.br

2. Types of Data collected

Among the types of Personal Data that Kobana collects, by itself or through third parties, there are: Tracker; Usage data; email; Universal unique identifier (UUID); All Data shared during the use of the service; unique device identification for advertising (Google Advertiser ID or IDFA, for example).

Directly Provided Data

Full name, email, date of birth, location, tax ID (CPF), address, phone number and social media profiles.

Data Sent by Clients

Information necessary for generating billing documents (bank slips, PIX and other financial instruments).

Technical Data

Operating system, IP address, geographic location information and device identification.

Third-Party Data

Publicly available data from social media or received from business partners.

Analytical Data

Collected through cookies, web beacons and pixels for analysis of Service usage.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific explanatory texts displayed before Data collection.

Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using Kobana.

Unless specified differently, all Data requested by Kobana is mandatory and failure to provide this Data may make it impossible for Kobana to provide its Services. In cases where Kobana specifically states that some Data is not mandatory, Users are free to not communicate this Data without any consequence to the availability or functioning of the Service.

Users who have questions about which Personal Data is mandatory are welcome to contact the Owner.

Any use of cookies -- or other tracking tools -- by Kobana or by the owners of third-party services used by Kobana shall be for the purpose of providing the Services requested by the User, in addition to the other purposes described in this document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Service (Kobana).

3. Mode and location of Data processing

Processing method

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, alteration or unauthorized destruction of Data. The technical and organizational measures adopted include:

Electronic and physical protection barriers
Firewalls and intrusion detection systems
Cryptographic protection of data in transit and at rest
Access authorization controls for information
Periodic security reviews with up-to-date technology
White Hat policy, with incentives and rewards for those who report security vulnerabilities

Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and means strictly related to the indicated purposes. In addition to the Owner, in some cases, the Data may be accessed by certain types of persons in charge, involved with the operation of this Service (Kobana) (administration, sales, marketing, legal, system administration) or external persons (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, when necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Location

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention period

Unless otherwise specified in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for, and may be retained for longer due to any applicable legal obligation or based on Users' consent.

4. Purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal and regulatory obligations, fulfill its contractual obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, provide support and ensure the security of Users, and evolve its Services with a personalized experience, as well as for the following:

Statistics
Tag management
User database management
Advertising
Displaying content from external platforms
Handling productivity-related activities
Remarketing and behavioral targeting

5. Detailed information about the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Statistics

Google Analytics (Universal Analytics)

Google LLC

Data: Usage data; Tracker

Location: USA

Google Analytics Demographics and Interest Reports

Google LLC

Data: Advertising ID; Tracker

Location: USA

User database management

Intercom

Intercom Inc.

Data: Usage data; email; UUID; Tracker; data shared during use

Location: USA

Tag management

Google Tag Manager

Google LLC

Data: Usage data

Location: USA

Handling productivity-related activities

Google Workspace

Google LLC

Data: Tracker

Location: USA

Advertising

Meta ads conversion tracking (Meta pixel)

Meta Platforms, Inc.

Data: Usage data; Trackers

Location: USA

Google Ad Manager

Google LLC

Data: Usage data; Tracker

Location: USA

Remarketing and behavioral targeting

Facebook Remarketing

Meta Platforms, Inc.

Data: Usage data; Tracker

Location: USA

Displaying content from external platforms

YouTube video widget

Google LLC

Data: Usage data; Tracker

Location: USA

6. Opting out of interest-based advertising

In addition to the opt-out feature provided by the services listed in this document, Users may learn more about how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

7. Cookie Policy

Kobana uses Trackers. To learn more, Users may consult the Cookie Policy.

8. Additional information for users

Legal basis for processing

The Owner may process Personal Data relating to the User if one of the following applies:

  • Users have given their consent for one or more specific purposes.
  • Provision of Data is necessary for the performance of a contract with the User and/or any pre-contractual obligations thereof.
  • Processing is necessary for compliance with a legal obligation to which the Owner is subject.
  • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner.
  • Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

More information about retention time

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

Personal Data collected for the purposes of the Owner's legitimate interests shall be retained as long as needed to fulfill such purposes.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfill a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

9. User Rights (GDPR)

Users have the following rights under the General Data Protection Regulation (GDPR):

Withdraw your consent at any time.
Object to the processing of your Data.
Access your Data.
Verify and request rectification.
Restrict the processing of your Data.
Have your Personal Data deleted or otherwise removed.
Receive your Data and have it transferred to another controller.
Lodge a complaint.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be addressed by the Owner as soon as possible and always within one month.

10. Additional information for Users in Brazil

This section applies to all Users in Brazil, in accordance with the "Lei Geral de Proteção de Dados" (the "LGPD").

On what basis we process your personal information

Legal bases:

User consentLegal or regulatory obligationPublic policiesStudies by research entitiesContract executionExercise of rights in proceedingsPhysical protectionHealth protectionLegitimate interestsCredit protection

Your privacy rights as a Brazilian citizen

You have the right to:

Obtain confirmation of the existence of processing activities.
Access to your personal information.
Correction of incomplete, inaccurate or outdated information.
Anonymization, blocking or deletion of unnecessary information.
Information about the possibility of providing or refusing consent.
Information about third parties with whom we share data.
Portability of personal information.
Deletion of personal information.
Withdrawal of consent at any time.
Complaint to the ANPD or consumer protection bodies.
Opposition to non-compliant processing activities.
Information about automated decision-making criteria.
Review of automated decisions.

Transfer of personal information outside of Brazil

Transfer is permitted in the following cases:

International legal cooperation
Protection of life or physical safety
Authorization by the ANPD
International cooperation agreement
Execution of public policy
Compliance with legal or contractual obligation

11. Data Sharing

Your data may be shared in the following situations:

Suppliers and service providers

We share data with service providers that we use as support for platform operation.

Clients

We receive and process data from clients who hire our services for billing generation.

Corporate operations

In cases of sale of our assets or as part of due diligence in merger or acquisition processes.

Public authorities

We share data to comply with requests from public authorities and investigate fraud or other illegal conduct.

12. Additional information about Data collection and processing

Legal action

The User's Data may be used for legal purposes by the Owner in court or in the stages leading to possible legal action arising from improper use of this Service or the related Services by the User.

System logs and maintenance

For operation and maintenance purposes, Kobana and any third-party services may collect files that record interaction with Kobana (system logs) or use other Personal Data (such as IP address) for this purpose.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying Users on this page and possibly within this Service and/or, to the extent technically and legally feasible, by sending a notification to Users via any contact information available to the Owner.

13. Definitions and legal references

Personal Data (or Data)

Any information that, directly or indirectly, allows the identification or makes it possible to identify a natural person.

Usage Data

Information collected automatically through Kobana (or third-party services employed), which may include IP addresses, URIs, request times, method used and other information about the User's environment.

User

The person who uses Kobana and who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Subcontractor)

The natural or legal person, public authority, agency or other body that processes Personal Data on behalf of the Controller, as described in this policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body that, individually or jointly with others, determines the purposes and means of processing Personal Data.

Kobana (or this Application)

The means by which the User's Personal Data is collected and processed.

Service

The service provided by Kobana, as described in the relative terms and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made in this document to the European Union include all current member states of the European Union and the European Economic Area.

Cookie

A tracker consisting of a small set of data stored in the User's browser.

Tracker

Any technology -- for example, cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting -- that enables the tracking of Users.

Contact

To exercise your rights or clarify questions about this Privacy Policy, contact us:

lgpd@kobana.com.br

Kobana Tecnologia Ltda.

Calçada das Margaridas, 163, Sala 02 Centro Comercial Alphaville - Barueri, SP - CEP 06453-038

CNPJ: 05.813.794/0001-26