Privacy Policy

TLK Consulting is committed to safeguarding personal privacy and protecting the

personal data of our employees, clients, suppliers and other entities with which we

conduct business. TLK Consulting’s Privacy Policy (the “Privacy Policy”) describes how

we gather and process personal information and provides a clear understanding of how

data (or “personal data”) is controlled and secured, and the rights of each person in

relation to their personal information.

Personal data and confidential information are key assets for TLK Consulting, and for

its clients and suppliers. TLK Consulting is committed to ensuring the security and

protection of personal information and is also committed to maintaining compliance

and consistency in the approach to data protection.

TLK Consulting complies with all regulatory requirements and any other legislation

regarding data protection in the countries that we hold subsidiaries, such as the EU

General Data Protection Regulation 216/679 act (“GDPR”), a regulation approved by the

European Union (EU) regarding data protection and privacy for all residents within the

EU, as well as the Law number 13.709/2018, a legislation approved by the Brazilian

Government regarding data protection and privacy for all residents within Brazilian

territory. Except where this policy explains otherwise, each TLK Consulting subsidiary

maintains individual control in relation to the personal data collected from its

employees, clients and suppliers, being considered the “controller” of the respective

personal data in accordance with the definition established on both legislations herein

mentioned.

TLK Consulting is a management consulting organization with headquarters in Brazil

and subsidiaries in United Kingdom, Germany, United States of America, Mexico, Chile

and Argentina.

Policy:

1. To whom this Privacy Policy applies

2. Personal information we collect

3. How we use personal data

4. Updates and communication

5. Who may receive your information

6. Where and how we store personal data

7. How we protect personal information

8. Individual rights related to personal information

9. TLK Consulting’s contact information

Personal Data Protection and Privacy Policy:

1. TO WHOM THIS PRIVACY POLICY APPLIES

1.1 This Privacy Policy applies to individuals that are or were representatives of TLK

Consulting’s clients or suppliers, employees or former employees of TLK Consulting,

candidates for a job within the organization, students, trainees and any other individual

that is or was a partner or associate of TLK Consulting.

2. PERSONAL INFORMATION WE COLLECT

2.1 TLK Consulting does not collect and process personal data without consent, except

when the information is necessary due to a contractual or legal obligation or when TLK

Consulting has a legitimate interest in collecting the information to accomplish its

management consulting activities. Thus, we may collect data from you if:

1. You are a prospective client, existing client or supplier of TLK Consulting;

2. You work or have worked for a client or supplier of TLK Consulting;

3. You are an employee, partner or associate of TLK Consulting;

4. You are candidate for a job position within TLK Consulting, or a prospective partner

or associate of TLK Consulting;

5. You work for a company to whom TLK Consulting wants to advertise or market its

services or events.

2.2 TLK Consulting may use all available methods to collect information, including but

not limited to, in-person communications, communication by phone, email, letter or

notice, other paper-based communication methods, etc. Our primary means of obtaining

personal data is directly from the person. Data that is not collected directly from the

person may be obtained through:

1. Your employer in connection with work that relates to us;

2. Third parties we work closely with, such as personal contacts, trustees, business

partners, subcontractors, or analytics and public information providers;

3. Government bodies;

4. Websites or other applications and platforms operated by TLK Consulting that are

utilized by the individual too.

2.3 We collect basic information that identifies each person as an individual and the

company the person represents, such as:

Business contacts of clients or suppliers

a. full name;

b. the name of the company you represent;

c. your job function and department;

d. business address;

e. business email;

f. private email;

g. business telephone and mobile phone;

h. month and day of your birth;

i. information to fulfill legal or contractual obligations.

Employees, job candidates, students,

trainees, associates and partners

All information necessary to complete the contractual obligation as a partner or associate

of TLK Consulting, as well as all personal data necessary to completing the employment

agreement.

2.4 Sensitive Personal Data: We may collect and process sensitive personal data when

it is relevant and necessary to the consulting management services TLK Consulting

provides, or required to fulfill a legal or contractual obligation; for example, life

insurance policies or specific activities of a client that require TLK Consulting to obtain

health reports.

2.5 Technical Data: TLK Consulting may store also the IP addresses of clients who

access TLK Consulting’s website and other platforms. Also, we store the navigation

data from internal users for audit purposes, including URLs, date/time and browsing

time, application type and protocols such as HTTP and FTP.

3. HOW WE USE YOUR PERSONAL DATA

3.1 TLK Consulting does not use personal data without first obtaining the consent of its

owner. Exceptions to this rule may occur if: (i) we are obliged by law; (ii) it is necessary

to completing a contractual obligation or to defending our rights; or (iii) it is necessary

to exercising TLK Consulting’s legitimate interest in processing your data to provide

management consulting services.

3.2 TLK Consulting does not disseminate, sell or commercialize personal information to

any third parties, or in any way identify the individual owner of personal information.

TLK Consulting may share information with third parties, or its subsidiaries for

processing. In this situation, TLK Consulting will continue to act as controller of the

information, and the third party, or subsidiary shall act according to this Privacy Policy.

3.3 Regarding business contacts, the processing of personal data is done for the

purpose of delivering and providing management consulting services, or to accept

services from the suppliers the individual represents. Personal data may also be

processed to make available relevant content to the owner of the information, such as:

1. Institutional messages;

2. Newsletters;

3. Event-related materials—invites, reminders and thank you notes;

4. Congratulatory, holiday and birthday cards;

5. Event materials produced by TLK Consulting;

6. Client feedback surveys.

3.4 Regarding TLK Consulting professionals (employee, associate, partner, ex-

employee, ex-associate or expartner) their data are stored and is subject to processing

for the purpose of managing the employment relationship, contractual obligation or due

legal obligation in accordance with TLK Consulting’s Internal Policies and/or local

legislation.

3.5 Candidates for jobs at TLK Consulting, as well as students and trainees engaged for

the purposes of recruitment, may also have their data, such as, but not limited to

resumes, profile, collected and stored by TLK Consulting to enable communications,

interviews and offers of employment. TLK Consulting will not store this information for

any longer than two years from the date of the initial interview or receipt of the job

application, whichever occurs later.

4. UPDATES AND COMMUNICATIONS

4.1 Where permitted in our legitimate interest, to fulfil a legal or contractual obligation

or with prior consent from the individual where required by law, we may use personal

data to request updates to TLK Consulting’s internal CRM (Client Relationship

Management) system.

4.2 You can opt out of receiving further marketing materials or communications from us

at any time by updating your contact details within your account or indicating this

preference through the “unsubscribe” link included at the end of all digital

communications addressed to you.

5. WHO MAY RECEIVE YOUR INFORMATION

5.1 We may share your personal information with any other subsidiary of TLK

Consulting as described herein this Privacy Policy. We may share information with a

third party regarding your contractual obligation with TLK Consulting to process or

support processing of personal data. In the event a third party receives individual

personal data, TLK Consulting will maintain a nondisclosure agreement and the data

will be strictly limited to the purpose agreed upon by TLK Consulting.

5.2 We may also share personal data with TLK Consulting business partners, suppliers

and subcontractors for the delivery of a contract we enter into under normal business

circumstances with you or the company you represent, with our auditors and with our

legal advisors when it is necessary.

5.3 TLK Consulting may disclose your personal data to appropriate third parties if it

sells any business or assets, in which case TLK Consulting must disclose personal data

to the prospective buyer of such business or assets.

5.4 TLK Consulting may disclose or share your personal data to comply with any legal

obligation, judicial or any authorities order.

6. WHERE AND HOW PERSONAL DATA IS STORED

6.1 The personal data that TLK Consulting collects might be transferred, stored and

processed in TLK Consulting’s headquarters. In addition, TLK Consulting may also

process data outside the EU either directly or by use of third parties contracted by us.

When necessary, TLK Consulting may transfer personal data to:

1. Enable TLK Consulting to provide services and fulfill its contract with an individual

or a company they represent;

2. Operate the business, where it is in TLK Consulting’s legitimate interests and the

company has

concluded there is no risk of infringement of individual rights surrounding the

information.

6.2 Personal data may be shared with the TLK Consulting subsidiaries listed herein this

obligations with individuals, clients or suppliers. If your information is transferred

outside EU, TLK Consulting will take all the steps reasonably necessary to ensure that

the data is treated securely and protected.

7. HOW PERSONAL DATA IS PROTECTED

7.1 We have put in place internal procedures that restrict access to personal data

except to those individuals who have a relevant business need. All individuals who have

contact with personal data are subject to TLK Consulting’s confidentiality policy.

7.2 We have also implemented security measures to prevent personal data from being

lost, used, altered, disclosed or accessed by unauthorized individuals.

7.3 The transmission of information via the internet is protected through best practice-

based technology, and continual updates to our platform. Transmission of information

through the internet is never 100% secure, but we are committed to protecting the

transmission of information through all reasonable measures; for example, use of

advanced encryption (AES 256, HTTPS, Bitlocker), internet links segmentation, SSL

certificates from external companies (DIGICERT), recurrent penetration tests in all

systems, and Wi-Fi and Endpoint protection such as Antivirus, Intrusion Prevention

System and Data Leak Prevention features.

7.4 We will only retain your personal data for as long as it is necessary to complete the

purpose we collected the information for, and to fulfill legal or contractual obligations.

7.5 Depending on the circumstance, we may anonymize personal data to avoid any

association with an individual.

8. INDIVIDUAL RIGHTS RELATED TO PERSONAL DATA

8.1 TLK Consulting will ensure your personal data is up to date and accurate. When

permitted by applicable legislation, you can request the correction, updating or deleting

of your personal data in part or total. In this situation, the individual shall contact us by

email at privacy@TLKConsulting.com. We will make all reasonable efforts to comply

with your request.

8.2 When permitted by local legislation and submitted by individual request, TLK

Consulting may provide the person with a copy of the respective personal data stored

and information on how the data has been processed. The individual may request that

TLK Consulting restrict or object to the sharing of personal data, and where the sharing

of data is based on consent, the individual has the right to withdraw consent at any

time.

8.3 An individual can exercise their rights by contacting TLK Consulting at

privacy@TLKConsulting.com. To comply with a request, TLK Consulting may need to

request specific information to confirm their identity, as well as take additional

appropriate security measures.

9. TLK Consulting’S CONTACT INFORMATION

9.1 TLK Consulting has designated a special team to develop and implement

compliance measures surrounding the new privacy and data regulations that are being

introduced. We understand that continuous employee awareness and education is

essential to compliance with these legal requirements that ensure the protection of

personal information worldwide.

9.2 If you have any concerns or questions about this Privacy Policy, please contact

privacy@TLKConsulting.com.

Privacy Policy

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