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.