Privacy Policy

FREIRE, ASSIS, SAKAMOTO E VIOLANTE ADVOGADOS

PRIVACY POLICY

Version: June 2022

The Privacy Policy (“Policy”) of FREIRE, ASSIS, SAKAMOTO E VIOLANTE ADVOGADOS, a law firm legally registered with the CNPJ/ME (Brazilian Registry of Corporate Taxpayers) under No. 03.510.322/0001-79 (“FASV”, “we”, “us” or “our” as applicable), has been created to demonstrate our commitment to the security and privacy of the information collected from our users, who are the owners of their personal data (“Individual”, “User”, simply “you”).

The Policy clarifies the general conditions for collection, use, storage, and other forms of processing and protection of personal data on our website http://www.fasvadvogados.com.br (“Website”), in accordance with the Brazilian laws in force on personal data privacy and protection, including, but not limited to, Law No. 12,965, dated April 23, 2014, and Decree No. 8,771, dated May 11, 2016 (“Civil Rights Framework for the Internet”), as well as Law No. 13,709, dated August 14, 2018 (“General Data Protection Act” or “LGPD”).

For the purposes of this Policy, FASV is qualified as the Data Controller as it stores your personal information, and is responsible for the decisions regarding the treatment of your personal data collected by us. In order to keep direct contact with you, FASV has appointed a Personal Data Handling Officer to manage a communication channel. If you have any queries related to the personal data treatment activities for which we are responsible or inquiry and comments regarding our Policy, please send an email to [email protected] for the attention of Amilcar Sakamoto (“The Officer”).

By using our Website, you are expressing in a free, informed, unquestionable, express, and complete agreement with this Policy. We recommend reading it carefully.

1. APPLICABILITY
2. INFORMATION THAT WE MAY COLLECT
3. THE LEGAL BASIS FOR HANDLING PERSONAL DATA
4. THE PURPOSE OF COLLECTION DATA
5. SHARING PERSONAL DATA
6. RIGHTS OF INDIVIDUALS
7. HOW WE STORE AND HANDLE PERSONAL DATA
8. INTERNATIONAL TRANSFER OF PERSONAL DATA
9. RETENTION TIME FOR INFORMATION
10. TERM AND AMENDMENTS
11. COMMUNICATION POLICY
12. LINKS TO OTHER WEBSITES

1. APPLICABILITY

This Policy applies to all the Website users, and your personal data is collected whenever you request to receive our Newsletter.

1. INFORMATION THAT WE MAY COLLECT

Note: You are not required to provide us with your information. However, if you do not provide certain information when this is required, you will not be to access some of our functionalities. In addition to the data that you are informing us, whenever you interact with our Website, information will be automatically collected. This information is not generally identifiable, however when combined with other information, it makes it possible to associate it to you, and therefore it is treated by FASV as personal data.

The nature and purpose of the personal data that we may collect may differ according to the Website area accessed.

Within the limits of the applicable laws, FASV may process the following personal data that are informed to us by you:

1. Information for sending newsletters: email, company, and field of work
2. b) Cookies and similar technologies: according to our Cookies Policy

Note that the above-listed personal data will be collected by FASV and processed later only to the extent necessary to achieve the purposes listed here.

We do not collect, save or otherwise intentionally process personal data that are excessive or unnecessary for the purpose for which it was collected, as well as data considered sensitive (those concerning your racial or ethnic origin, religious conviction, political opinion, membership with a union or religious, philosophical, or political organization, health, or sexual orientation, as well as genetic data) and data of on minors. In view of that, we ask you to refrain from sharing such data with us. If we are aware that there has been an unauthorized collection and processing of such data, they will be deleted from our records.

1. THE LEGAL BASIS FOR HANDLING PERSONAL DATA

The legal basis of the data stored and processed by FASV, as listed in Section 2, is determined by the analysis of the specific context in which we collected it.

The data processed by FASV tend to be collected only:

1. Upon your consent;
2. For the purposes of legal or regulatory obligation;
3. When the personal data is being handled for the legitimate interests of FASV and with due consideration for your interests in relation to data protection or fundamental liberties or rights. It may also be necessary to process your data to protect your interests or those of third parties.

1. THE PURPOSE OF COLLECTION DATA

We collect information for the sole and exclusive purpose of maintaining and improving the services available so that we can provide you with a better experience. Therefore, we collect information, when necessary to use for the following purposes:

1. Sending our Newsletter;
2. Improving our Website;
3. Submitting information to government authorities when requested through notifications, court orders, or other legal proceedings to establish or exercise our legal rights or protect our property; to defend ourselves from legal claims or as required by law.

5. SHARING PERSONAL DATA

When necessary to achieve the purposes described in Section 4, FASV may share your personal data with third parties listed below aiming to provide the services offered correctly, keep your personal data secure and provide you with a better experience with FASV. Whenever done, the sharing of data will be done within the limits and purposes of our business, in accordance with the purpose of the personal data processing and as authorized by the applicable laws. Thus, your data may be shared with:

1. The MailChimp platform for automatic submission of our Newsletters;
2. Providers of computing and information technology services and service-providing companies with a focus on ensuring the security of the information processed by FASV;
3. Tax authorities and government, police, public, and judicial authorities for the purpose of answering to complaints, investigations, court orders, and legal proceedings, if requested, as well as to comply with legal, regulatory and tax obligations.

6. RIGHTS OF INDIVIDUALS

Under the relevant legislation, you, as the subject of the personal data, may contact us to exercise your rights, in order to request:

1. a confirmation of the existing processing of y our personal data;
2. an access to your data;
3. a correction of your incomplete, inaccurate, or outdated data;
4. anonymization, blocking, or elimination of your data that are unnecessary, excessive, or processed in disagreement with the provisions of the applicable laws;
5. portability of your data to another service or product vendor, subject to trade and industrial secrets;
6. elimination of your personal data, except in the events provided in the applicable laws, for exercises of rights in connection with FASV and compliance with legal requirements;
7. Information on which public and private entities FASV shared your data with;
8. information on the possibility that you will not provide consent and the consequences of such a refusal;
9. withdrawal of your consent, when you have given it, subject to any public interest that may justify a continued processing or any other existing legal grounds authorizing it; and
10. an opposition to any processing of personal data on the grounds of one of the events in which your consent can be waived, provided that there has been some noncompliance with the applicable laws and subject to any public interest that may justify a continued processing.

Your request may be filed for free by sending an email to [email protected].  We will analyze your request and deal with it as soon as possible, bearing in mind the timescales and conditions established in the relevant legislation. If we are unable to immediately deal with your request immediately, we will indicate the factual and legal reasons preventing us.

FASV is not responsible for the data provided by the Individual being correct, true, genuine, complete and up to date, nor for any possible misuse or fraudulent use of the information.

The Individual is the only party liable for providing only information that is accurate, true, authentic, complete, and up-to-date.

7. HOW WE STORE AND HANDLE PERSONAL DATA

FASV has security, technical, and administrative measures in place to keep all stored data secure according to corporate guidance, confidentiality clauses, and a strict access control, with our employees only accessing data that are strictly necessary to meet their specific needs, as provided in Section 4. Specifically with regard to the data collected through our Website, they are stored, processed, and protected according to the best hosting and processing practices.

Even so, individuals should be aware that no Internet security system is guaranteed against unwanted access, and FASV’s commitment is limited to putting in place protection measures that are recommended according to the current state of the art.

8. INTERNATIONAL TRANSFER OF PERSONAL DATA

FASV may transfer some of your personal data to other countries or international bodies only when strictly necessary to achieve the purpose that led to the processing of your personal data, prioritizing whenever possible storage on servers located in the Federative Republic of Brazil. When your personal data is transferred out of Brazil by FASV, we will take appropriate action to ensure adequate protection to your personal data in accordance with the requisites of the applicable data protection laws, including by entering into appropriate agreements on data transfers with third parties, when necessary.

9. RETENTION TIME FOR INFORMATION

We store and keep your information: (i) for the length of time required at law; (ii) until termination of the personal data processing, as mentioned below; (iii) for the time required to protect FASV’s legitimate interest, as applicable; (iv) for the time required to safeguard a regular exercise of FASV’s rights in a judicial, administrative, or arbitration proceeding; Therefore, we will continue to handle your data, for instance, during the applicable limitation periods or as long as necessary to perform a legal or regulatory obligation.

Termination of the personal data will take place in the following events:

1. When the purpose for which the Individual’s personal data was collected has been achieved and/or the personal data collected cease to be relevant necessary for or applicable to such purpose;
2. When the Individual withdraws their consent or it is in their right to request termination of the processing and exclusion of their personal data and has done so; and
3. When there is a legal mandate in that regard.

Subject to the principle of necessity, some data submitted through the Website may be deleted from our records in the course of routine record maintenance. We are in no obligation to retain personal data indefinitely and disclaim all responsibility arising from or relating to the deleting this personal data.

Upon termination of the processing of your personal data, except for the events established in the applicable laws or this Privacy Policy, they will be deleted from FASV’s database. If it is not possible to delete them immediately, the data will be stored securely and isolated from any further processing until it can be deleted.

10. TERM AND AMENDMENTS

Our Website, in whole or in each of its tabs and sections, may be unilaterally shut down, suspended, or interrupted by FASV at any time and with no need for prior notice, in which case we will inform where the information contained in it that you have a right to access under the laws in force will be available.

This Privacy Policy may be updated or amended at any time, with any changes being  prominently informed on our Website.

11. COMMUNICATION POLICY

We try to avoid sending unsolicited emails and limit our communications with you to subjects that are relevant or in your specific interests.

If you would rather not receive our information anymore, you can request your subscription cancellation by clicking the cancellation link contained in the very email received (opting out).

You must be aware that several fraudsters attempt to make use of renowned brands to obtain personal information such as passwords and financial information. FASV WILL NEVER REQUEST FINANCIAL DATA BY EMAIL OR TELEPHONE WITHOUT PRIOR DIRECT COMMUNICATION FROM MEMBERS OF OUR TEAM WHO ARE DIRECTLY RELATED TO THE SUBSCRIBED SERVICES. IN CASE OF ANY SUSPICIOUS ATTITUDE, SUBMIT YOUR QUESTION OR WARNING BY EMAIL TO [email protected].

12. LINKS TO OTHER WEBSITES

Our Website may contain links to or frames from other websites. These links or frames seek to provide benefits that are additional to the contents and services offered to the User.

We should clarify that the inclusion of those links in our Website does not mean that FASV has consented to, agrees with, or is responsible for the contents of said links and frames. It is important to highlight that our goal is to only provide links or frames from good-standing, reliable companies, and FASV is not liable for any information, products, and services obtained by the User on said websites nor for the business practices and privacy policies employed by these companies, it being agreed that FASV cannot be held liable for any losses and damage or lost profit sustained as a result of the use of such resources.

As the linked websites are not part of our Website, we do not control, recommend, or endorse these websites and their contents, products, services, policies, and their privacy practices; we do not have any access to your personal data collected and processed by them and their advertising policies, cookies policies, and terms of use. We thus recommend reading these third-party website documents carefully.

By accessing our Website and interacting with us, you agree with and accept the terms laid out here.