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This Privacy Policy is governed by current Brazilian legislation, especially Law 13,709/18 (“General Data Protection Law”) and Law 12,965/14 (“Marco Civil da Internet”).
For the purposes of this Privacy Policy, the following definitions are established:
Holder: natural person (clients, employees, partners, suppliers and providers) to whom the personal data that are subject to processing refer;
Personal Data: is information related to an identified or identifiable natural person. It may include, for example, name, address, email, telephone, debit/credit card number, IP address and geolocation data;
Sensitive personal data: special category of personal data relating to racial or ethnic origin, religious belief, political opinion, membership of a trade union or organisation of a religious, philosophical or political nature, relating to health or sexual life, genetic or biometric data relating to the natural person;
Anonymized Data: is information that, alone or in conjunction with other Anonymized Data, does not allow the identification of a person, considering the use of reasonable and available technical means at the time of its processing. It may include gender, age and generalized geolocation (such as the city in which the person is located) and statistical data;
Database: structured set of personal data, established in one or more locations, in electronic or physical support;
Processing of personal data: any operation carried out with personal data, such as those referring to: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction;
Controller: natural or legal person, under public or private law, responsible for decisions regarding the processing of personal data;
Operator: natural or legal person, under public or private law, that processes personal data on behalf of the controller;
Person in charge / DPO: person appointed by the controller and operator to act as a communication channel between the controller, data subjects and the National Data Protection Authority (ANPD);
User: people who access or interact with activities offered on the different internet portals owned by the Office and client companies;
The processing of personal data by Mazzucco e Mello will have the following purposes:
The Holders are guaranteed the fundamental rights of freedom, intimacy and privacy, ensuring ownership of their Personal Data contained in physical and electronic records, files, records and other inherent information and documents that are archived and under the direct responsibility of the Office or its service providers duly contracted for this purpose, as well as their respective sources, it being understood that certain services provided on the websites may contain specific particular conditions in relation to data protection.
The Holder also has the following rights, specifically in relation to his/her Personal Data, in accordance with current legislation:
To ensure that the Data Subject can exercise these rights relating to their Personal Data, the Office, in compliance with legal provisions, has a Personal Data Governance area, accessible solely and exclusively through the following direct service channel:
Contact email: leonardo.neri@br-mm.com
The Holder may formalize a request, at any time, directed to the channel above and/or others eventually made available for this purpose and duly communicated.
The Office will process the Data Subject’s request and provide whatever is requested promptly, always complying with the legal and regulatory deadlines determined by the National Data Protection Authority (“ANPD”).
The Office informs that it adopts all security measures usually practiced by the market and appropriate, aiming at the protection of Personal Data against unauthorized access, alteration, disclosure or destruction.
These measures include internal reviews of our data collection, storage and processing practices and security measures, including encryption and appropriate physical security measures to guard against unauthorized access to systems where we store personal data.
The Holder is solely and exclusively responsible for any and all passwords required by the electronic systems made available by the Office, and his/her password is personal and non-transferable. He/she must ensure its use and adopt all reasonable security measures when accessing the electronic systems made available by the Office.
However, the Holder must be aware that the security measures relating to the world wide web, the internet, are not entirely secure, and are subject to actions by malicious third parties and, therefore, the Holder, when accessing the Office's digital platforms, must ensure that all security measures are installed on their access equipment, such as, but not limited to, firewall and antivirus.
The Office does not request passwords from Holders, nor changes and/or updates to registrations, except through its own official communication channels, and no third parties are authorized for this purpose.
The Office undertakes to promptly communicate to the Data Subject and the ANPD (National Data Protection Authority) the occurrence of any security incidents that may entail any relevant risks or damages, collaborating with any investigations and acting effectively to repair any losses.
The Office may share Personal Data with other companies in the same group, whether controlling or controlled by the latter, directly or indirectly, always with respect to the same purposes that were indicated in this Policy and in current legislation.
Additionally, the Office will share data with partner companies and suppliers duly contracted and authorized for this purpose ('Operators'), in the development and provision of legal services made available to the Data Subject, considering contractual safeguards to guarantee the security of Personal Data and the Data Subject's rights, allowing only the processing of Personal Data for specific purposes and in accordance with the Controller's instructions.
The Office will share the information and respective documents and Personal Data in the cases provided for by law and/or with the prior consent of the Holder, in which case the Office will request express authorization to share all information and documents.
Additional considerations
The Holder guarantees that the Personal Data provided to the Office are true and legitimate, free from any defects in consent, and also undertakes to immediately communicate to the Office any changes thereto.
Except in fields where otherwise indicated, answers to questions about Personal Data are optional, and their absence does not imply a reduction in the quality or quantity of the corresponding services.
The Office may decide to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, are impractical, or for which access is not otherwise required.
The Office will provide Data Subjects with adequate resources so that they can, in advance, agree with this Policy or any other relevant information before giving their consent to the storage of their Personal Data.
This Privacy Policy may, at Mazzucco e Mello's discretion, be updated and/or changed at any time, without prejudice to the rights of Data Subjects guaranteed by current legislation, and such update will be explicitly announced by the Firm, through its communication channels, including the respective highlight in the Policy itself. Any updates and/or changes that affect the rights of Data Subjects and/or obligations of the Firm, as well as those arising from current legislation, may be subject to specific communication.