Last updated on January 05, 2022

This Privacy Policy (“Privacy Policy”) was prepared by Freitas Ferraz Advogados, with the aim of informing our clients, potential collaborators and interested third parties about the way in which we collect, store, protect and use their Personal Data. 

The protection of your Personal Data is of great importance to us and, for this reason, we follow strict policies for Processing, in accordance with the relevant legal and regulatory standards, aiming to guarantee and respect your privacy and provide transparency to the processes carried out with the your Personal Data.

This Privacy Policy aims to: 

a) Reinforce our commitment to privacy and security in the Processing of Personal Data;

b) Demonstrate, in a simple and transparent way, what Personal Data we process, the reason and the way used to collect, store, process, transfer and consult said data;

c) Describe your rights related to Personal Data and the way in which such rights can be exercised; It is

d) Present how we protect your Personal Data.

Therefore, in addition to accepting our Terms of Use and consulting our Cookies Policy, you need to know our Privacy Policy, which has clear and complete information about how Freitas Feraz collects, uses, stores, processes and protects your Personal Data. 

The Privacy Policy is subdivided into the following sections:

Section Theme
1 What concepts are important for understanding this Privacy Policy?
2 How does Freitas Ferraz collect your Personal Data?
3 What Personal Data is processed by Freitas Ferraz?
4 What are the purposes of Freitas Ferraz for the Processing of Personal Data?
5 What are the legal bases for the Processing of Personal Data? 
6 Who can we share your Personal Data with?
7 Transfers of your Personal Data outside Brazil
8 How long do we store your Personal Data?
9 What are your rights and how can you exercise them?
10 How do we keep your Personal Data safe?
11 How can you contact Freitas Ferraz?
12 General Provisions

 

1. WHAT CONCEPTS ARE IMPORTANT FOR UNDERSTANDING THIS PRIVACY POLICY?

1.1 We know that some terms used in this Privacy Policy may not be common in your daily life. Therefore, we have prepared a small glossary for you to consult its definitions: 

A

Treatment Agents: are the agents responsible for the Processing of Personal Data, being the Controller and the Operator;

Anonymization: technique through which data loses the possibility of association, directly or indirectly, with an individual, so that it becomes impossible to identify the Holder of the anonymized data;

ANPD: is the National Data Protection Authority, a federal public administration body with responsibilities related to the protection of Personal Data and privacy, including monitoring compliance with the LGPD throughout the national territory. 

B

Legal base: These are the grounds provided for in the LGPD to authorize the Processing of Personal Data by a Processing Agent. The LGPD provides that any and all Processing, regardless of its size or criticality, must be legitimized on a legal basis in order to be considered valid before the law. The legal bases are mainly present in articles 7 and 11 of the LGPD.

C

Consent: is the free, informed and unequivocal expression by which the Holder agrees to the Processing of their Personal Data for a specific purpose;

Controller: refers to the natural or legal person responsible for decisions regarding the Processing of Personal Data;

D

Personal Information: is all information that allows the direct identification of a natural person or that can make that person identifiable. Examples of Personal Data are: name, address, CPF, ID, email, identity documents in general, telephone number, records of access to internet applications (date and time of use of a particular internet application, IP address used for access), among others;

Sensitive Personal Data: are Personal Data related to racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data when linked to a natural person;

Device: means any electronic device used by you to access Freitas Ferraz systems, such as desktop computers, laptops, televisions, cell phones, tablets, smartphones and/or other devices connected to the internet;

E

In charge: is the person designated by the Processing Agents to act as a communication channel between the Controller, Personal Data Holders and the ANPD and to ensure that the Processing Agents are in compliance with data privacy laws and regulations. Contact information for Freitas Ferraz's Manager is available in section 11 of this Privacy Policy; 

IP adress: is the number assigned to each Internet-connected Device, known as an Internet Protocol address (Internet Protocol or IP). Generally, these numbers are assigned in geographic blocks. An IP address can be used to identify, for example, from which location a Device is connecting to the Internet;

F

Freitas Ferraz: means, jointly, Freitas Ferraz Capuruço Braichi Riccio Sociedade de Advogados, a law firm registered with the CNPJ under No. 25.095.994/0001-06 and Freitas, Ferraz Sociedade de Advogados, a law firm registered with the CNPJ under No. 30.488.441. 0001/45-XNUMX, exclusive domain owners https://www.freitasferraz.com.br/

L

GDPR: means the General Personal Data Protection Law, Federal Law No. 13.709, published on August 14, 2018, which regulates Personal Data Processing activities, including in digital media, by natural persons or legal entities governed by public law or private, with the aim of protecting the fundamental rights of freedom and privacy and the free development of the personality of the natural person. The full content of the LGPD can be consulted on this link;

O

Operator: is the natural or legal person that carries out the Processing of Personal Data on behalf of the Controller, following its instructions;

P

Potential Collaborator: are individuals who are interested in working or providing services for Freitas Ferraz, by sending a professional CV through the channels indicated on our website or through vacancy websites;

T

Headline: is the natural person to whom the Personal Data that is the subject of Processing refers;

Treatment: any operation carried out with Personal Data, whether automated or not. In other words, it is the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, archiving, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction of Personal Data;

1.2. If you still have questions after reading the terms defined above, please contact us through the service channel indicated in section 11 of this Privacy Policy.

 

2. HOW DOES FREITAS FERRAZ COLLECT YOUR PERSONAL DATA?

2.1. Method of collecting Customers’ Personal Data. Our customers' Personal Data may be collected directly from them or via third parties involved in the provision of our services, (i) at the time of commercial negotiations or the formalization of proposals for the provision of services; (ii) during the provision of legal services, when such information is not obtained at the time of implementing the business proposal; and/or (iii) providing documents that are necessary to fulfill the purposes set out in section 4 of this Privacy Policy.

2.2. Method of collecting Personal Data from Potential Employee. Potential Employee's Personal Data may be collected by filling out forms, responding to questionnaires and/or providing documents that contain Personal Data, such as professional CVs, in events promoting Freitas Ferraz's professional opportunities and/or in procedures related to Freitas Ferraz’s selection processes.

2.3. Personal Data collected automatically via the Platform. We may collect some files and/or information stored on your Devices when you visit our website. These files or information are called “cookies” and are used to facilitate the use and optimize the use of our websites according to your interests, preferences and needs. If it is of interest to you, cookies can be disabled through the browser used to access the Platform. To learn more about the use of cookies by Freitas Ferraz, see our Cookies Policy. 

2.4. The veracity and accuracy of the information provided by the Holder to Freitas Ferraz is the sole responsibility of the Holder. Providing incomplete or false data may constitute a crime.

2.5. Holders may, at any time, request specific information about the Processing of their Personal Data by Freitas Ferraz, through the service channel indicated in section 11 of this Privacy Policy.

 

3. WHAT PERSONAL DATA ARE PROCESSED BY FREITAS FERRAZ?

3.1. Freitas Ferraz will process the Personal Data indicated below, to the extent necessary to achieve any of the Processing purposes set out in section 4 of this Privacy Policy:

Sensitive Personal Data  Personal Data/Sensitive Personal Data processed
CUSTOMER Registration data, such as name; RG; CPF; marital status; naturalness; professional record; address; email; telephone; financial data; Bank data; sex; profession; workplace.
POTENTIAL CUSTOMER Registration data, such as name; email; city; telephone and workplace.
POTENTIAL COLLABORATOR Registration data, such as name; email; telephone; academic training and schooling.

 

3.2. In addition to the Personal Data mentioned in the table above, Freitas Ferraz may request additional Personal Data from Holders to complete any service and/or request through any of Freitas Ferraz's service channels. In this case, you will always be informed of the purpose for which Personal Data is being requested.

3.3. Freitas Ferraz undertakes to use the minimum amount of information necessary to achieve the intended Processing purpose, therefore limiting itself to the use of pertinent, proportional and non-excessive data. 

3.4. Freitas Ferraz may collect other Personal Data and/or Sensitive Personal Data from the Holder, as necessary to achieve the purposes set out in section 4 below and always in accordance with the criteria and procedures set out in the LGPD.

3.5. You may, at any time, request specific information about which Personal Data is subject to Processing by Freitas Ferraz, through the service channel indicated in section 11 of this Privacy Policy.

 

4. WHAT ARE THE PURPOSES OF FREITAS FERRAZ FOR PROCESSING PERSONAL DATA?

4.1. Freitas Ferraz seeks to process your Personal Data always based on legitimate, specific, explicit and informed purposes. In this sense, we detail below the main purposes underlying the Processing of Personal Data and/or Sensitive Personal Data:

Purpose of Treatment Headlines
CUSTOMER POTENTIAL CUSTOMER POTENTIAL COLLABORATOR
Enable the offer and provision of services by Freitas Ferraz
Presentation and conclusion of commercial proposals and contracts
Expertise in judicial, administrative or arbitration proceedings
Acting in demands of a consultative nature in the areas of Law in which Freitas Ferraz operates
Communicate with the Holder through Freitas Ferraz communication channels
Shipping newsletter and/or educational materials
Comply with legal and/or regulatory obligations
Defend the interests of Freitas Ferraz in administrative, arbitration or judicial proceedings
Carry out the recruitment and selection process of employees for Freitas Ferraz

 

4.2. Freitas Ferraz is completely against any and all practices that promote spam of any kind. Therefore, it is committed to ensuring that the messages sent are always of interest or importance to the respective recipients.

4.3. You may, at any time, choose to receive or not receive emails from Freitas Ferraz. To do this, simply adjust your preferences for receiving emails.

4.4. You may, at any time, request specific information about the Processing of your Personal Data by Freitas Ferraz, through the service channel indicated in section 11 of this Privacy Policy.  

 

5. WHAT ARE THE LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA?

5.1. In accordance with the provisions of the LGPD, all Processing of Personal Data must be validated based on the Legal Bases set out in articles 7 and 11 of the LGPD. In this sense, Freitas Ferraz clarifies that the Processing of your Personal Data may be carried out based on the following Legal Bases:

(i) Upon provision of Consent by the Holder of Personal Data: in the remote cases in which it is necessary to process Personal Data based on Consent, we will only process Personal Data whose Processing was authorized voluntarily and through your free, informed consent and unequivocal;

(ii) To comply with legal or regulatory obligations by the Controller: as in the case where we will need to comply with obligations inherent to the nature of our activity;

(iii) When necessary for the performance of a contract or preliminary contract-related procedures: such as in the situation where we will need to process Personal Data to fulfill our contractual obligations;

(iv) For the regular exercise of rights in judicial, administrative or arbitration proceedings: as in the situation in which we will need to process Personal Data to advise our clients in defenses and monitoring of judicial, administrative or arbitration actions;

(v) When necessary to meet the legitimate interests of the Controller or third parties.

5.2. In relation to Sensitive Personal Data which, in turn, pose greater risks to the Holder and have specific Legal Bases for their Processing provided for by the LGPD, Freitas Ferraz may justify the processing of Sensitive Personal Data based on the following Legal Bases:

(i) Consent of the Holder and/or their legal guardian: in the remote cases in which it is necessary to process Sensitive Personal Data based on Consent, we will only process Sensitive Personal Data whose Processing was authorized voluntarily and through your free consent , informed and unambiguous;

(ii) To comply with legal or regulatory obligations by the Controller: as in the case where we will need to comply with obligations inherent to the nature of our activity;

(iii) For the regular exercise of rights, including in contracts and in judicial, administrative and arbitration proceedings: as in the situation in which we will need to process Personal Data to advise our clients in defenses and monitoring of judicial, administrative or arbitration actions.

5.3. The entire Processing of Personal Data and/or Sensitive Personal Data carried out by Freitas Ferraz is legitimized on one of the legal bases indicated above. To ensure this adequacy, we periodically review our processes, considering the context in which they operate, the risks and benefits that may be generated for our customers, potential employees and/or third parties. Furthermore, we maintain records of all our Processing operations, which may be the subject of requests for clarification by the Personal Data Holder, as well as by competent public authorities.

5.4. It is important that you are aware that, as detailed in items 5.1 and 5.2 of this Policy, we will not always need your Consent to use your Personal Data. As seen above, there are situations in which, for various reasons, we may use your information without relying on the legal basis of Consent (such as, for example, if we are obliged by law to use your Personal Data or if we need your Personal Data to the purposes set out in a contract).

5.5. However, whenever we need your Consent to use your Personal Data for a specific purpose, you will be informed before any information is collected. At that time, we will make it clear to you why we will need your Personal Data and you will be able to choose whether or not to provide us with your information.

5.6. If you choose to provide your Consent for the informed Processing purpose, we will formalize your expression of will by signing and/or accepting a term describing the situation. If you are not interested in providing your Consent, we will inform you of the consequences of this refusal.

5.7. You may, at any time, revoke the consent previously provided to Freitas Ferraz, if applicable, by expressing yourself expressly through the service channel indicated in section 11 of this Privacy Policy.

 

6. WHO CAN WE SHARE YOUR PERSONAL DATA WITH?

6.1. To achieve the purposes described in section 4 of this Privacy Policy, your Personal Data may be shared with some recipients, such as:

(i) Our commercial partners and service providers, when necessary for the purpose of enabling the services provided by Freitas Ferraz, such as, for example, service providers of (i) infrastructure and technology necessary for the operational performance of Freitas Ferraz, (ii) cloud computing, (iii) data backup, (iv) issuing invoices, (v) organization of events, fairs and workshops, (vi) expertise and technical assistance in judicial, administrative or arbitration proceedings, when applicable, (vii) accounting and/or auditing;

(Ii) Public bodies, competent authorities and insurance companies, when necessary to comply with legal and/or regulatory obligations and/or for the regular exercise of Freitas Ferraz's rights in arbitration, administrative or judicial proceedings;

(iii) The legal entities involved in any corporate transaction that involves the restructuring of the business group of which Freitas Ferraz is part, when necessary to make the corporate transaction in question in which Freitas Ferraz and its assets are involved viable;

(Iv) Other third parties, provided that at the express request of the Holder, in accordance with section 9 of this Policy;

(V) Notary and Property Registry Offices, Commercial Boards and other regulatory bodies, when necessary to provide our services.

6.2. The service providers mentioned in item (ii) above are hired by Freitas Ferraz as Operators.

6.3. With the aim of providing maximum security to commercial relationships involving the Processing of Personal Data, Freitas Ferraz certifies, prior to hiring an Operator, that they have an adequate technical, legal and organizational structure compatible with strict governance, security criteria and privacy of Personal Data.

6.4. Operators will only be authorized to process Personal Data upon receipt of lawful instructions provided by Freitas Ferraz, which will be in strict accordance with the provisions set out in this Privacy Policy and the LGPD.

6.5. Any sharing of Personal Data will be carried out in the minimum form necessary to achieve a legitimate purpose, in accordance with the security and confidentiality standards established by the LGPD and other laws, rules and regulations related to the protection and privacy of Personal Data.

6.6. In situations where Personal Data has been collected through the collection of Consent, Freitas Ferraz undertakes to obtain your specific Consent for the purposes of sharing Personal Data with other Controllers and Operators, except in the cases of waiver of Consent provided for by the LGPD .

6.7. You may, at any time, request specific information about the third parties with whom Freitas Ferraz shares your Personal Data, through the service channel indicated in section 11 of this Privacy Policy.

 

7. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE BRAZIL

7.1. Freitas Ferraz may transfer your Personal Data to commercial partners and/or service providers located outside Brazil, such as, for example, cloud document storage service providers. Whenever it is necessary to transfer Personal Data outside Brazil, we will adopt all necessary measures to ensure adequate protection and security of all information, within the limits provided for by the LGPD and other laws, rules and regulations related to the protection and privacy of Personal Data . Furthermore, we will always use third-party services that have market-appropriate standards regarding the protection and security of Personal Data.

 

8. HOW LONG DO WE STORE YOUR PERSONAL DATA?

8.1. The Personal Data provided by you to Freitas Ferraz will be stored on its own or contracted servers nationally or internationally, for a period defined as follows:

(i) the period required by laws, resolutions and/or other regulations to which Freitas Ferraz is subject;

(ii) the time necessary to achieve the purpose of Processing Personal Data, as listed in section 4 of this Privacy Policy;

(iii) the time necessary to preserve the legitimate interests of Freitas Ferraz, as applicable; or

(iv) the time necessary to protect the regular exercise of Freitas Ferraz's rights in judicial, administrative or arbitration proceedings, including in compliance with the applicable statute of limitations.

8.2 With the exception of cases in which legislation authorizes the maintenance of your Personal Data by Freitas Ferraz, they will be deleted when:

(i) the purpose of the Processing is achieved;

(ii) the Personal Data are no longer necessary or relevant to achieve the specific purpose sought;

(iii) in applicable cases, you exercise your right to revoke Consent, by means of communication; or

(iv) there is a determination by the ANPD, in case of violation of the LGPD. 

8.3. You may, at any time, request the deletion of your Personal Data stored by Freitas Ferraz, provided that such data (i) is unnecessary, excessive or treated in non-compliance with the LGPD or (ii) has been made available through the provision of Consent. The deletion request may be made through the service channel indicated in section 11 of this Privacy Policy.

8.4. Freitas Ferraz undertakes to make its best efforts to respond to all requests for the deletion of Personal Data as quickly as possible, as long as they are permitted in accordance with applicable legislation. 

 

9. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

9.1. You, as a Personal Data Holder, have a series of rights provided for by the LGPD, including:

(i) Confirmation of the existence of Treatment: You can ask Freitas Ferraz to confirm that your Personal Data is being processed.

(ii) Access to Personal Data: you can request Freitas Ferraz to access the Personal Data under Processing. In this case, Freitas Ferraz will provide, by electronic or physical means, a copy of your Personal Data stored by us. Freitas Ferraz cannot provide Personal Data from other customers and/or third parties.

(iii) Correction or updating of Personal Data: You can request correction or updating of your Personal Data when it is inaccurate, incomplete or out of date. Before updating your Personal Data, Freitas Ferraz may request documents and/or information that prove the information provided.

(iv) Request the Anonymization, blocking or deletion of Personal Data: You can request that Personal Data that is unnecessary, excessive or processed in non-compliance with the LGPD be anonymized, blocked or deleted from the Freitas Ferraz database.

(v) Personal Data Portability: You may request the migration of your Personal Data collected by Freitas Ferraz to another organization after regulation on the subject by the ANPD.

(vi) Deletion of Personal Data: You can request the deletion of your Personal Data processed by Freitas Ferraz based on your Consent, at any time, through free and facilitated expression, and Personal Data will not be deleted in cases whose conservation is authorized by the LGPD.

(vii) regarding the sharing of Personal Data: you may request information about sharing your Personal Data with third parties.

(viii) Information about the possibility of not providing Consent: you can request information about the possibility of not providing Consent for the Processing of your Personal Data by Freitas Ferraz, at which time Freitas Ferraz will inform you about the consequences of this refusal which, in some situations, may make it impossible to offer certain products and services .

(ix) Revocation of Consent: You can revoke the Consent provided to Freitas Ferraz for the Processing of Personal Data for certain purposes, at any time. It is important to highlight that the request to revoke Consent will not imply the deletion of Personal Data that is maintained by the Freitas Ferraz based on other legal grounds.

(x) Opposition to Treatment: you can oppose the Processing of Personal Data carried out by Freitas Ferraz based on one of the legal hypotheses for waiving Consent and which is not in line with the provisions of the LGPD.

(xi) Reporting to ANPD and consumer protection bodies: you can report to the ANPD and/or consumer protection agencies about any incidents related to your Personal Data.

(xii) Automated decision review and explanation: You can request that Freitas Ferraz review decisions made solely based on automated processing of Personal Data and that affect your interests, including decisions aimed at defining your personal, professional, consumer, credit profile, or aspects of your personality, as well as requesting clear and adequate information regarding the criteria and procedures used for automated decision-making, respecting commercial and industrial secrets.

9.2. To exercise the rights described above, you may send a communication via email to [email protected].

9.3. To comply with the rights exercised under this section and in order to guarantee the security of Personal Data, Freitas Ferraz may request information and documents for the purpose of proving the identity and authenticity of the requester.

 

10. HOW DO WE KEEP YOUR PERSONAL DATA SECURE?

10.1. Freitas Ferraz uses all reasonable efforts to ensure the security of systems used in the Processing of Personal Data, such as:

(i) technical measures capable of keeping Personal Data safe and protected from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication or any other form of inappropriate or unlawful Processing, in accordance with data protection rules applicable data and information security, in accordance with best market practices;

(ii) storage of Personal Data processed by Freitas Ferraz in secure databases, with access restricted only to employees with the appropriate credentials;

(iii) awareness of Freitas Ferraz employees about good compliance practices and Personal Data protection, in accordance with the LGPD; It is

(iv) signing of contracts with employees and service providers who have access to Personal Data processed by Freitas Ferraz, with clauses relating to data protection, aiming to establish the obligation to maintain absolute secrecy and confidentiality of the data accessed, under penalty of civil and criminal liability, under the terms provided for in Brazilian legislation.

10.2. Our website may contain links that will direct you to other pages, including those of partners, which have policies with provisions different from those set out in this document. Therefore, Freitas Ferraz is not responsible for the collection, use, sharing and storage of your data by those responsible for such pages outside the Freitas Ferraz domain Platform.

 

11. HOW CAN YOU CONTACT FREITAS FERRAZ?

11.1. If you have any questions, complaints and/or need to communicate with Freitas Ferraz regarding topics related to the protection of Personal Data, please contact our Person in Charge: 

In charge: Adriano Augusto Teixeira Ferraz – email: [email protected] 

 

12. GENERAL PROVISIONS

12.1. This Privacy Policy may be changed by Freitas Ferraz at any time. If you wish to check which version of the Privacy Policy is in force at the time of your inquiry, simply check this information in the header of this Privacy Policy. The most current version of this policy will always be available at https://www.freitasferraz.com.br/politica-de-privacidade/

12.2. If we make any changes to this Privacy Policy that, in our sole discretion, are material, we will notify you by email where appropriate.

12.3. By continuing to access our website or use our services after the effective date of such change, you accept and agree to be bound by the revised version of the policy. 

12.4. This Privacy Policy will be governed and interpreted in accordance with the laws of the Federative Republic of Brazil.

12.5. If any provision contained in this Privacy Policy is considered invalid, illegal or unenforceable in any respect, the validity, legality or enforceability of the other provisions contained in this Privacy Policy will not in any way be affected or impaired as a result of such fact.

12.6. The court of the district of Belo Horizonte, state of Minas Gerais, is elected as the only one competent to resolve any disputes regarding the interpretation and compliance with this Privacy Policy. However, before starting a formal legal process, you can always count on the support of the Freitas Ferraz team to resolve your problems in a more agile and non-confrontational way, simply by contacting us through the service channel indicated in section 11 of this Privacy Policy.