Effective from July 1, 2020
As part of our commitment to respecting your
privacy, Pinheiro Neto Advogados (Pinheiro
Neto) has created this privacy policy (Policy)
to explain what Personal Data are collected and how they are processed by
us.
We recommend that you read this Policy carefully. It describes how we
collect and process your personal information when you access and use
Pinheiro Neto platform, as necessary for us to make available the platform
functionalities.
For the purposes of this Policy, "Users" means
all individuals that in some way use Pinheiro Neto platform.
Our online platform can be accessed through
URL
http://www.pinheironeto.com.br/
(Platform),
on which Users can register for newsletters or events.
If you are a legal entity, you must register
as a Platform User through a duly authorized legal representative. For the
purposes of this Policy, when the User is a legal entity, its legal
representative will also be deemed a "User" to the extent his or her
personal data are provided and processed on the Platform.
We do not collect or knowingly request
information from individuals under 18 years. Users less than 18 years of age
should not send information through our Platform. If we learn that we have
collected information from an individual under the age of 18, we will delete
that information from our databases.
For our Platform to offer effective functionalities, it must have
access to certain personal information about Users (collectively, "Personal
Data").
We are unable to offer the Platform functionalities without having access to
your Personal Data, i.e. processing of your Personal Data is a condition for
using the Platform.
This Policy explains, in a simple,
straightforward and transparent way, what types of Personal Data we collect
and process about you and the purposes for which they are collected and
processed, with whom they may be shared, and the resources available to
Users to manage their Personal Data.
Please refer to the content of this Policy:
1. What Personal Data do we collect and
process?
2. Why do we collect and process Personal
Data?
3. When do we erase Personal Data?
4. Who else will have access to Personal
Data and why?
5. What are your rights in and to your
Personal Data?
6. How do we store and protect your Personal
Data?
7. Are you required to give your consent for
Pinheiro Neto to use your Personal Data as described in this Policy?
8. Third-Party Websites
9. Changes to this Policy
10. How to make a complaint
Under Law 13,709/2018, Pinheiro Neto is deemed the "Processor" of
your Personal Data in the context of its legal services, so the information
described throughout this document contemplates solely the data processed by
Pinheiro Neto through the Platform. If you have any questions about this
Policy or, for any reason, need to report any issue regarding your Personal
Data, please contact us via the following channels:
privacidade@pn.com.br
Data Protection Officer:
Raphael de Cunto
1. What Personal Data do we collect and process?
Registration Data: Pinheiro Neto only receives or otherwise collects
the following information about Users when they register on the Platform:
• name;
• organization for which they work;
• position within the organization;
• e-mail address; and
• language for correspondence (nationality).
Device Information: we can also collect device information, such as
IP, date and time you access the Platform. It is important to mention that
we do not collect personal data by means of cookies, pixels, beacons, or
other similar tools. The use of cookies by the Platform is solely for
statistical analyses of the Platform activity, without any association to
the IP or other Personal Data of Users.
2. Why do we collect and process Personal Data?
We use Personal Data of Users for the following purposes:
Data |
Purpose |
Registration Data |
•
Register Users to receive newsletters through the
Platform; and
•
Register Users to attend Pinheiro Neto events.
|
Device Information |
Comply with legal obligations. |
We do not use User Personal Data for any
purpose other than as described above.
3. When do we erase Personal Data?
We have structured the Platform and our
operations to avoid keeping your Personal Data identified for longer than
necessary. In other words, we keep your Personal Data only for the period
necessary for the purposes described above, when required by law, or for
regular exercise of our rights.
We can maintain the Personal Data in
anonymized form, in which they are or can no longer be associated to a User,
for longer periods.
4. Who else will have access to Personal Data and why?
We may share your Personal Data with other
Pinheiro Neto offices and/or with the third parties identified below, which
are engaged to assist us in carrying out the purposes mentioned in item 2
above.
Some of these offices and third parties may be
located abroad. If there is a cross-border transfer of your Personal Data,
we will take the measures prescribed by law to ensure their continuous
protection, but you should bear in mind that, when you use the Platform and
provide us with your Personal Data, they may be sent to other countries.
Third Party |
Type of data shared |
Purpose of sharing |
Business partners, such as event
reception and organization companies |
• Registration Data |
• Register Users to
receive newsletters through the Platform; and
• Register Users to attend
Pinheiro Neto events.
|
Judicial, police or governmental
authorities or other third parties with whom we are required by law,
regulation or court order to share Personal Data |
• Registration Data
• Device Information
|
• If we are required, by a court order or in compliance
with a legal or regulatory obligation, to disclose certain Personal
Data about our Users to judicial, police or governmental
authorities. |
5. What are your rights in and to your Personal Data?
Under the General Data Protection Act (LGPD or
Law 13,709/2018), you have the right to request:
i.
confirmation that we processed your Personal Data;
ii.
access to your Personal Data;
iii.
rectification of incomplete, inaccurate or outdated Personal Data about
you;
iv.
anonymization, blocking or erasure of Personal Data deemed unnecessary,
excessive, or processed in breach of the LGPD;
v.
portability of your Personal Data to another service or product supplier,
with due regard for our trade or industrial secrets, in accordance with the
regulation to be issued by the National Data Protection Authority;
vi.
erasure of Personal Data processed on the basis of your consent, unless they
need to be retained in the events prescribed by the LGPD;
vii.
information about the persons with whom we share your Personal Data;
viii.
information about the possibility of refusing consent and consequences of
refusal;
ix.
withdrawal of your consent for processing of your Personal Data, where they
are processed on the basis of your consent (please refer to item 7 below);
x.
objection to the processing where it is in violation of the LGPD.
You can exercise any of these rights by
sending an e-mail to
privacidade@pn.com.br.
Before responding to your request, we can ask
you to provide some information to confirm your identity.
6. How do we store and protect your Personal Data?
We store your Personal Data in a secure system
of Pinheiro Neto in Brazil. We adopt the best technical and administrative
practices to protect Personal Data from unauthorized access, destruction,
loss, alteration, disclosure or other form of improper or unlawful
processing.
We know that no Platform is completely secure.
If you have any concern or suspicion that your Personal Data are at risk,
for example, if someone had unauthorized access to your Personal Data,
please contact us immediately.
7. Are you required to give your consent for Pinheiro Neto to use your
Personal Data as described in this Policy?
The LGPD establishes a number of situations in
which the processing of Personal Data is permitted without the consent of
the data subject to whom they relate. These situations involve the so-called
"legal bases for the processing of data."
Therefore, if you opt to use the Platform, in
some cases we can collect and process your Personal Data without your
consent (if there is a "legal basis" in the LGPD authorizing us to do so).
In other instances, we will obtain your consent to use your Personal Data
accordingly.
Pinheiro Neto obtains, in accordance with this
Policy, your consent solely to the processing activities necessary for your
registration on the Platform to receive our newsletters and attend our
events. If there is any change in the processing of Personal Data and your
consent is required, you will be informed (see item 9 below) so that your
consent can be duly obtained pursuant to the LGPD.
8. Third-Party Websites
As a resource to our Users, we can provide
links to other websites operated by third parties on the Internet. Pinheiro
Neto does not take any responsibility for such third-party websites and
their content, and does not share, endorse, monitor, validate or accept the
way these linked websites or content storage tools collect, process and
transfer your personal and private information. We recommend that you
consult the privacy policies of the linked websites for proper details about
the use of your personal information by any such websites or tools.
9. Changes to this Policy
We may revise this Policy at our discretion
and at any time.
If we make substantial changes to this Policy,
they will be valid, effective and binding after: (1) they are disclosed on
the website of Pinheiro Neto; (2) they are notified to Users by
e-mail; and/or (3) they are notified to Users by other means.
Users must consult the updated version of this
Policy every time they visit the Platform.
Where changes to this Policy result in
modifications in our processing activities that depend upon Users' consent
(see item 7 above), Users will be requested to consent to the new terms of
this Policy after the relevant changes so that they can continue using the
Platform and receiving the Services.
10. How to make a complaint
You can make a complaint via Pinheiro Neto's
channels informed above.
You can also send a message to the National
Data Protection Authority.