Privacy Policy

BVZ Advogados, on its own behalf and on behalf of its staff, recognizing the importance of and duty to protect the privacy of personal information and documents provided by external and internal users (hereinafter “Data Subjects”) in BVZ Advogados’ various databases, including its internet portals and physical documents in its custody, and acting as the Controller of the processing of such personal data, hereby establishes this Privacy Policy.

APPLICABILITY

This Privacy Policy applies solely and exclusively to the clients and personal data subjects of BVZ Advogados.

APPLICABLE LEGISLATION

This Privacy Policy is governed by current Brazilian legislation, particularly Law No. 13,709/18 (the “Brazilian General Data Protection Law”) and Law No. 12,965/14 (the “Brazilian Internet Civil Rights Framework”).

DEFINITIONS

For the purposes of this Privacy Policy, the following definitions apply:

• Data Subject: a natural person (clients, staff, partners, suppliers, and service providers) to whom the personal data being processed relates;
• Personal Data: information relating to an identified or identifiable natural person. This may include, for example, name, address, email address, telephone number, debit/credit card number, IP address, and geolocation data;
• Sensitive Personal Data: a special category of personal data concerning racial or ethnic origin, religious beliefs, political opinions, membership in a trade union or an organization of a religious, philosophical, or political nature, health or sex life, and genetic or biometric data relating to a natural person;
• Anonymized Data: information that, either on its own or in combination with other Anonymized Data, does not allow a person to be identified, considering the use of reasonable technical means available at the time of processing. This may include gender, age, generalized geolocation (such as the city in which the person is located), and statistical data;
• Database: a structured set of personal data maintained at one or more locations, in electronic or physical form;
• Personal Data Processing: any operation performed on personal data, including collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination, or extraction;
• Anonymization: the use of reasonable technical means available at the time of processing through which data can no longer be associated, directly or indirectly, with an individual;
• Consent: a freely given, informed, and unambiguous indication by which the Data Subject agrees to the processing of their personal data for a specific purpose;
• Controller: a natural person or legal entity, governed by public or private law, responsible for decisions concerning the processing of personal data;
• Processor: a natural person or legal entity, governed by public or private law, that processes personal data on behalf of the Controller;
• Data Protection Officer / DPO: a person appointed by the Controller and Processor to act as a communication channel between the Controller, Data Subjects, and the Brazilian National Data Protection Authority (ANPD);
• User: individuals who access or interact with activities offered on internet portals owned by BVZ Advogados and companies within its corporate group, under its direct or indirect control.

PURPOSE OF THE PRIVACY POLICY

The purpose of this Privacy Policy is to inform Personal Data Subjects of the guidelines for collecting, processing, storing, and protecting physical and digital information and documents (hereinafter “Personal Data”) collected by BVZ Advogados or on its behalf, or entered directly by their Data Subjects (external and internal) into its digital and physical platforms. It explains how their Personal Data will be processed, their rights, and how those rights may be exercised.

PERSONAL DATA PROCESSING

Data collected by BVZ Advogados may be processed in accordance with the principles established in the Brazilian General Data Protection Law, always observing good faith, and incorporated into the corresponding physical and electronic records (hereinafter “Records”) or Databases for which BVZ Advogados will act as Controller.

BVZ Advogados clarifies that the Personal Data collected will be processed only for lawful purposes and objectives, with the Data Subject’s consent or on a legal basis, including when necessary to serve the legitimate interests of BVZ Advogados, provided that these do not conflict with the Data Subject’s fundamental rights and freedoms requiring the protection of personal data.

Data that undergoes anonymization (“Anonymized Data”) during processing will not be considered Personal Data for the purposes of this Privacy Policy, as it can no longer be associated, directly or indirectly, with an individual, in accordance with current legislation.

PURPOSES OF PERSONAL DATA PROCESSING

The processing of personal data by BVZ Advogados will serve to fulfill legal or regulatory obligations, pursue legitimate, specific, and explicit purposes in accordance with current legislation, and perform contracts to which the Data Subject is a party.

TYPES OF PERSONAL DATA THAT MAY BE COLLECTED AND PROCESSED

• Registration and/or contact data;
• Professional and/or legal data;
• Identification data issued by official bodies;
• Financial/payment data;
• Data concerning the Data Subject’s preferences (e.g., data based on internet browsing on its own or related websites).

METHODS OF PERSONAL DATA COLLECTION

• Provided directly by the Data Subject or their legal representatives: personal data entered, physically provided, or submitted when accessing one of our channels (websites or applications), or when making inquiries, applying for, and/or contracting products and/or services provided by BVZ Advogados;
• Collected directly by BVZ Advogados with the Data Subject’s consent: data collected during business processes, communication campaigns, or through authorized third parties, whether or not related to prospecting and the sale of products and services by BVZ Advogados;
• Provided by contracted third parties: Personal Data received from third parties working in partnership with BVZ Advogados, such as service providers that enrich information collected directly by BVZ Advogados, provided that this is expressly authorized by the Data Subject;
• Collected from public databases: data from public databases made available by authorities (such as the Brazilian Federal Revenue Service), credit institutions or credit protection agencies, or data explicitly made public by the Data Subject, for example, on websites or social networks, while safeguarding the Data Subject’s fundamental rights and freedoms requiring the protection of Personal Data;
• Collected automatically: information collected automatically and associated with personally identifiable information through technological tools such as Cookies, with the Data Subject being informed of all such collection. Examples of automatically collected data include your IP address, the date and time of website use, your location, information about your device, and information about your browsing habits.

PERSONAL DATA PROCESSING PERIOD

Personal Data will be processed for the entire period:

• During which the Data Subject accesses the BVZ Advogados website;
• Required by law or specific regulation;
• Necessary to fulfill the purposes of processing;
• Necessary to enable the regular exercise of the Firm’s or its clients’ rights in judicial, administrative, or arbitration proceedings, or during audits; and
• Determined by a competent authority.

TERMINATION OF DATA PROCESSING

The processing of Personal Data will end when:

• Its purpose has been achieved, or your personal data is no longer necessary or relevant to the specific intended purpose;
• You request termination in relation to personal data provided directly by you;
• The national authority orders its termination.

RIGHTS OF PERSONAL DATA SUBJECTS

Data Subjects are guaranteed the fundamental rights to freedom, intimacy, and privacy, and ownership of their Personal Data contained in physical and electronic databases, files, records, and other related information and documents stored under the direct responsibility of BVZ Advogados or its service providers duly contracted for this purpose, as well as information concerning their respective sources. Certain services provided on the websites may have specific conditions concerning data protection.

Under current legislation, Data Subjects also have the following rights specifically concerning their Personal Data:

• Confirmation of whether their Personal Data is being processed;
• Access to their Personal Data;
• Correction of incomplete, inaccurate, or outdated Personal Data;
• Anonymization, blocking, or deletion of unnecessary or excessive Personal Data, or Personal Data processed in violation of current legislation;
• Portability of their Personal Data to another service or product provider, upon express request, in accordance with the national authority’s regulations and subject to the protection of trade and industrial secrets;
• Deletion of Personal Data processed with their consent, subject to legal exceptions;
• Information about the public and private entities with which BVZ Advogados has shared their Personal Data;
• Information about the possibility of withholding consent and the consequences of doing so; and
• Withdrawal of consent to the processing of their Personal Data, in accordance with current legislation.

CONTACT CHANNEL FOR THE DATA PROTECTION OFFICER (DPO)

To ensure that Data Subjects can exercise these rights concerning their Personal Data, BVZ Advogados, in compliance with legal requirements, maintains a Personal Data Governance department accessible solely and exclusively through the following direct contact channel:

Contact email: contato@bvzadvogados.com.br

Data Subjects may submit a formal request at any time through the channel above and/or any other channels made available for this purpose and duly communicated. Requests will be addressed promptly, within the applicable legal deadlines.

PERSONAL DATA PROTECTION MEASURES

BVZ Advogados adopts all legally required security measures to protect Data Subjects’ Personal Data, including internal reviews of our data collection, storage, and processing practices and security measures, as well as encryption and physical security measures.

Incidents involving Personal Data that may cause harm to Data Subjects will be reported to the ANPD (Brazilian National Data Protection Authority). BVZ Advogados will cooperate with any investigations and take effective action to remedy any resulting harm.

PERSONAL DATA SHARING

Personal Data may be shared, in the circumstances provided for by law and/or with the Data Subject’s prior consent, with other companies within the same group, companies that directly or indirectly control or are controlled by it, and its subsidiaries and affiliates, always respecting the purposes stated in this Policy and current legislation.

Additionally, BVZ Advogados will share data with partner companies and suppliers duly contracted and authorized for this purpose (“Processors”), subject to contractual safeguards to ensure the security of Personal Data and the Data Subject’s rights. Personal Data may only be processed for specific purposes and in accordance with the Controller’s instructions.

COOKIES

By accepting this Privacy Policy, the Data Subject agrees to the processing of cookies in accordance with the definitions and terms set out below.

Definition: Cookies are data files stored on the device of a website or portal visitor (via smartphone, tablet, or computer). They record information such as user preferences, location, and pages visited, among other details, and make browsing more convenient.

Classification:

• By duration:

Session cookies: temporary cookies that remain until the web page or browser is closed. They may be used in e-commerce to analyze internet traffic patterns and provide users with a better experience and contextualized content.

Persistent cookies: cookies that remain even after the browser has been closed. They may be used, for example, to remember users’ login details and passwords or to ensure a better user experience across different sessions.

• By purpose:

Strictly necessary cookies: essential to enable users to use the websites, applications, and services offered, which could not be properly provided without these Cookies. They are generally session cookies.

Performance cookies: collect anonymous information about how users use and interact with the websites, applications, and services offered, allowing user profiles to be identified and visits and interactions to be counted.

Functionality cookies: remember choices made by users (such as login details and location) and provide more personalized experiences, as well as enabling customization where available. This information may be anonymized (becoming Anonymized Data), and these cookies do not track activities outside the websites, applications, and services offered. They are generally persistent cookies.

Analytics and advertising cookies: enable advertisers and partners to deliver more relevant advertisements and information to users. They are also used to limit the number of times users see certain advertisements and measure the effectiveness of advertising campaigns. They remember certain user preferences and help build user profiles to improve the user experience. They are generally persistent cookies.

How BVZ Advogados may use cookies:

BVZ Advogados may use cookies when a user accesses internet portals owned by it or companies within its corporate group.

Cookies are associated solely with the browser of a particular computer and do not provide references from which the user’s first and last names can be determined.

Cookies may allow BVZ Advogados to recognize users who registered during a previous visit to its pages, so they do not have to register again on each new visit.

Cookies used on the websites and web pages of BVZ Advogados’ internet portals may originate from the various servers it operates or from third-party servers that provide services and install cookies on behalf of BVZ Advogados.

Users are not required to accept cookies sent by BVZ Advogados to use its internet portals. However, in this case, users will need to register each time they access a service requiring prior registration.

Unless the option to prevent cookies from being installed has been enabled, users may search their computer’s hard drive in accordance with their browser’s instructions. Information about these settings is available in the browser’s own instructions and manuals, as illustrated by the examples below.

Internet Explorer: Cookie management instructions

Mozilla Firefox: Cookie management instructions

Chrome: Cookie management instructions

Safari: Cookie management instructions

The proper functioning of internet portals owned by BVZ Advogados and companies within its corporate group cannot be guaranteed if strictly necessary cookies are rejected.

ADDITIONAL CONSIDERATIONS

The Data Subject guarantees that the Personal Data provided to BVZ Advogados is true and legitimate, that consent is free from any defects, and undertakes to immediately notify BVZ Advogados of any changes to such data.

Unless otherwise indicated in specific fields, answering questions about Personal Data is optional, and failure to answer will not reduce the quality or quantity of the corresponding services.

BVZ Advogados will provide Data Subjects with appropriate means to agree to this Policy or review any other relevant information before giving their consent to the storage of their Personal Data.

CHANGES TO THIS POLICY

This Privacy Policy may be updated and/or amended at any time at the discretion of BVZ Advogados, without prejudice to Data Subjects’ rights guaranteed by current legislation. Any changes will be highlighted in the Policy and, where applicable, may be communicated separately.