We, at Stüssi-Neves Advogados, offer a wide
range of legal services, mainly focused on companies, in the most diverse
business segments. We also disclose, through our website and other digital
platforms (such as e-mail and social media), legal content and information on
matters that may be of interest to our clients and/or the general public.
By the very nature of our profession, we
have legal obligations regarding the confidentiality of the information
provided to us, but in addition, we are committed to safeguarding your privacy
and giving due protection to your personal data, whether you are our client or
not. The purpose of this document is to clarify what personal data we collect
from our clients, former clients, potential clients, service providers,
suppliers and other people with whom we maintain contact, by any platform or
means of communication, and how this data is treated.
If you do not agree with the contents of
this document, we do not recommend downloading our materials or using any of
our services.
First of all, we list below some
information that will help you better understand our Privacy Notice:
Privacy is a right that is guaranteed not
only by the Federal Constitution, but also by sectorial legislation, such as
the Civil Rights Framework for the Internet and the Consumer Defense Code, and
especially Law 13.709/2018, known as the General Law of Personal Data
Protection ("LGPD").
The LGPD contains a number of important
concepts, among which we highlight the following:
Personal Data - information that allows individuals to
be identified (for example, name, identity number, CPF, address, bank details,
etc.);
Sensitive Personal Data - personal data concerning
more intimate aspects of the data subject, that need greater protection, such
as data of racial or ethnic origin, religious convictions, political opinions,
among others, as expressly set out in the LGPD;
Data Subject – the “owner” of the data, that is, the
person to whom the data refers. You are the owner of your personal and
sensitive data.
Data Processing - any action that can be performed with
your data, involving your entire "life cycle". It includes, for
example, access, collection, processing, storage, disposal;
International transfer of data – the transfer of personal
data to a foreign country or international agency;
Anonymization - the technical procedure used to prevent
certain data from being linked to a certain person. The anonymized information
is not considered personal data for the purposes of the LGPD.
Which data are processed
In the exercise of our activities, we can
process personal data of our former, current and potential clients, employees,
business partners, suppliers, service providers and other people with whom we
maintain some degree of contact, as follows:
(i) On our website, we may collect data due
to your navigation on the website, by means of cookies. Cookies are small text
files that are generated by a website, sent to the browser and saved on the
hard drive of the device (computer, notebook, cell phone, tablet, etc.) and
that contain information relating to the navigation of the device on the
website (e.g. pages visited, date of visit, time etc.).
Based on their functionalities, cookies are
classified as: necessary, or related to performance, functionality and
marketing.
Currently we do not use cookies. However,
we may use cookies in the future, in which case you will be informed
specifically, when accessing our website, as to which types of cookies will be
used, and you will be able to agree or not with them.
(ii) provided by you (or your representative)
and/or collected from our direct contacts with you, in person, via e-mail,
telephone, virtual platforms or any other mode of interaction, especially with
the purpose of providing the services provided by this office;
(iii) data collected by third parties with
whom we have contact (e.g. from service providers, commercial partners etc.).
(iv) data made public by you or data access
to which is public, through research, verification, investigations and/or other
legally valid means to allow our adequate provision of services.
We will only
process personal data (both ordinary and sensitive) to the extent necessary for
performance of our contracts, to comply with legal or regulatory obligations, in
furtherance of legitimate interests or other situations authorized by the LGPD.
Purposes for which data will
be processed
We may use your personal data for different
purposes, as long as this is supported by one of the legal bases permitted in the
LGPD. As an example, we may mention the following purposes:
i. the
sending of newsletters, free material and/or information regarding services,
all with relevant legal content, although you can unsubscribe at any time. In
all e-mails we send there is always a link at the end of the e-mail that allows
you to cancel the receipt of our e-mails. For this purpose, we use, particularly,
your name, e-mail address, company where you work and your position/function;
ii. presentation
of lectures, seminars, webinars, workshops and/or any other form of
presentation of our content. For this purpose, we use, particularly, your name,
e-mail address, company where you work and your position/function and any other
data you provide;
iii. analysis,
review and preparation of documents and/or information of interest to us and/or
our clients, issuing opinions, the defense and/or representation of our clients
and/or our own defense and/or representation, in the administrative and/or judicial
area. For this purpose, we may use, especially, your contact information,
including name, identity number, CPF, address, landline and cell phone, e-mail
address, occupation, position of the data subject in the company/client,
information contained in documents and/or messages that you make available to
us or that were obtained from consultations with public departments, as well as
any other data that is related to the specific services that we provide;
iv. sharing
legal content in social media, such as Linkedin, Facebook, Instagram and
others, when you have expressly stated the desire to "follow" the
official page of this office in those media, in which case personal data may be
requested, as long as these are strictly necessary for the purposes required.
Besides personal data that may be requested directly from you, we have access
to data that you share in your social media, as from the moment we become part
of your network in such media.
Storage
The personal data will only
be stored for as long as necessary to fulfill the purposes for which we collected
them, including for the purpose of complying with any legal or contractual
obligations, for the rendering of accounts or if required by competent
authorities.
All your data collected will be deleted from our
servers, or if not anonymized, when you so request, or when they are no longer
necessary or relevant for us to offer our services, unless there is any other
reason for their maintenance, such as a possible legal obligation to retain
data.
Your Rights
As holder of the personal data, you have
the following rights guaranteed by the LGPD:
i. Confirmation
of existence of the processing;
ii. Access
to the data;
iii. Correction
of data that are incomplete, inaccurate or out-of-date;
iv. Anonymization,
blocking or deletion of data that are unnecessary, excessive or processed
otherwise than in accordance with the LGPD;
v. Portability
of the data to another service or product provider, when expressly required, in
accordance with regulations of the national authority, respecting commercial
and industrial secrets;
vi. Deletion
of personal data processed with the consent of the holder, except in the event
of compliance with a statutory or regulatory obligation, guaranteeing anonymization
of the personal data whenever possible;
vii. Information
from public and private entities with whom we share the use of data;
viii. Information
regarding the possibility of withholding consent and the consequences of
refusal;
ix. Revocation
of consent;
x. Opposition
to processing carried out based on one of the cases in which consent is not
required, in the event of non-compliance with the LGPD;
xi. Petition
to the National Data Protection Authority, in the event of any failure on our
part to respect your rights, and the issue is not resolved after your request
to us to remedy the situation.
Security of your data
We adopt the technical measures necessary to protect your data, such as:
(i) control over access to the data, by determining the persons who will
be able to access them;
(ii) password policy, with strong password standardization and blocking
of unsuccessful email attempts;
(iii) the environments where we process your data allow identification
of accesses to the connection records and access to our system’s databases;
(iv) maintenance of updated inventory of all data stored, processed or transmitted;
(v) firewall, which establishes the rules for external and internal
access to our network;
(vi) updated antivirus, providing a constant monitoring against threats.
In addition, any information forwarded by the holders will be protected
in accordance with strict standards of confidentiality and will only be used
for the purposes for which it was collected.
Information of (of for) Third Parties
We are not responsible for information published in
other websites, links to which may be mentioned in our website.
We undertake not to sell, rent or pass on
your information to third parties. However, we may share your data in certain
situations, always in a transparent manner and in line with the guidelines contained
herein, with the following persons/entities:
(i) service providers and business partners,
whenever the sharing is essential for performing the activities of the office, in
which case they are also obliged to guarantee the protection of your personal
data;
(ii) counterparties, for preparation, analysis
and/or execution of documents, in which you participate or are an interested
party;
(iii) government authorities and agencies
(especially administrative agencies and judicial bodies), for the defense of
rights in the administrative or judicial area, or otherwise by reason of
obligations imposed by laws or regulations.
International Transfer of Data
We maintain business
relationships with clients, service providers and partners in Brazil and
abroad. In addition, our services may involve actions to be performed in other
countries. Thus, the international transfer of data of certain holders may
occur in the course of our activities. However, we undertake to carry out the
international transfer of data only to the extent that this may be necessary,
always observing the requirements of the applicable legislation and existing
regulations, in order to guarantee adequate protection of such personal data.
Copyright
All the material exhibited on our website is protected by intellectual
property laws and may not be reproduced and/or distributed without our express
authorization.
Changes to Privacy Notice
This Privacy Notice may be updated from
time to time. Accordingly, we recommend that you visit this page periodically in
order to keep aware of the changes.
Doubts:
If you have any doubts regarding this
privacy notice, please get in touch with us via the following e-mail: privacidade@stussinevessp.com.br
Privacy Notice last updated on February 26,
2021.