PRIVACY POLICY

Latest version: February 14, 2019

GUSMÃO & LABRUNIE ADVOGADOS (“Gusmão & Labrunie”), enrolled as a taxpayer under CNPJ/MF n. 03.415.856/0001-16, with registered offices at Avenida Brigadeiro Faria Lima 1485, 11th floor, Jardim Paulistano, São Paulo/SP, CEP 01452-002, Brazil, complies with rules pertaining to the protection of privacy and personal data and, accordingly, it developed the present Privacy Policy, which provides for the processing of personal data of those accessing its website www.glpi.com.br (“Website”).

For purposes of this Policy, the term “User(s)” refers to any and all individual browsing Gusmão & Labrunie’s and/or accessing any of the functionalities available therein not otherwise regulated by a specific Privacy Policy.

1. DATA COLLECTED AND PURPOSE OF THE COLLECTION

• User’s data, including personal data, may be collected starting from his interaction with the Website, particularly and moreover to allow (i) the User’s adequate contact with Gusmão & Labrunie and (ii) the remittance of newsletters, as well as (iii) to ensure browsing in restricted access areas, such as the “Client Area”, which will only occur by means of a login and password and is governed by its own rules.
• Data collection by Gusmão & Labrunie is made as follows:
Information provided directly by the User: Gusmão & Labrunie collects personal data directly provided by the User, for instance upon completing online forms for purposes of contact and remittance of newsletters, which may include: (i) name; (ii) position held; (iii) company or entity to which he/she is related; and (iv) contact information , including e-mail and phone number.
Automatically collected information: Whenever the User visits the website, Gusmão & Labrunie may automatically collect information such as (i) the IP address; (ii) the device identification (ID or IMEI Code, for instance); (iii) the type of navigator and language; (iv) data regarding the sequence of clicks in the Website; (v) time of access and interaction with the Website; and (vi) other automatically collected data, such as that obtained by means of cookies (as provided of in item 3 of this Privacy Policy).
Such information allows Gusmão & Labrunie to have a better understanding of its Users, their location and the contents of the Website in which they have interest, and is used for analytical purposes and to improve the quality and materiality of the Website.
• Other Information: Gusmão & Labrunie will also collect information provided by the User in his communication and/or interaction (such as when the option “like” is selection, for example) with the office, by means of social networks, or to staff recruitment agencies engaged by Gusmão & Labrunie when applying for a job opening offered by us. Such information is exclusively used for purposes of selection and recruitment of candidates.
• Other information may also be collected for purposes of compliance with laws and binding government rules, as well as with lawful interests of Gusmão & Labrunie.

2. LEGAL BASIS FOR PROCESSING AND SHARING OF DATA

• Legal basis for the collection and use of the aforementioned personal information depends on the type of personal data in question and the context in which it was collected. However, Gusmão & Labrunie would normally collect personal data when it has consent from the User, when such data is required for the performance of an agreement with the User, or when the processing of persona data is carried out aiming at the best lawful interest of Gusmão & Labrunie. In some cases, Gusmão & Labrunie may be under a legal obligation to process some personal data or to file an administrative or judicial defense.
• Information collected by Gusmão & Labrunie may be shared as follows:
Gusmão & Labrunie may share information collected with any person authorized by the User.
Gusmão & Labrunie may share information collected from Users with police or judicial authorities, appropriate government authorities or other third parties, if so required by the applicable legislation.
• In case of corporate transactions, such as restructuring, merger or sale of Gusmão & Labrunie, the collected data may be transferred, provided that the terms of this Privacy Policy are duly observed. The same may occur in the event of a court-supervised reorganization or bankruptcy.
• User acknowledges and agrees that aggregate and anonymized information may be freely shared by Gusmão & Labrunie.

3. COOKIES

Gusmão & Labrunie uses cookies so as to allow the operation of certain aspects of the Website and do not store any data liable to directly identify the User. Gusmão & Labrunie also use cookies allowing it to verify the number of visits, traffic and interaction in the Website. Such cookies are used to generate aggregate data and anonymized analytical reports.
• User may manage his preferences of cookies and other technologies from the settings of its browser or device, however, depending on the choices made, this will prevent the working of some features of the Website.

4. DATA STORAGE AND SECURITY

Gusmão & Labrunie takes precaution measures, among which are administrative, technical and physical steps consistent with the state of the art and its economic size and business, to protect its personal information against loss, theft, undue use, as well as against unauthorized access, disclosure, modification and destruction.
• Professionals at Gusmão & Labrunie having access to the collected information are subject to specific confidentiality rules and other policies applicable by Gusmão & Labrunie to its business partners, employees and associates.
Gusmão & Labrunie has no liability whatsoever for the quality of the connection used by Users to access Website.
Gusmão & Labrunie maintains Users’ personal information stored for the time required to satisfy the purposes established in this Privacy Policy, taking into account any duty to retain information established by the law.
• User may request to Gusmão & Labrunie the exclusion of personal information provided to t. In the event that such exclusion is requested, the User’s information shall be definitively excluded whenever the law shall so determine. In some cases, however, the information may be retained, such as, for instance, to comply with any agreed obligation, to be used to solve litigations and/or for other reasons allowed by or resulting from the law.
• IN CONSENTING TO THIS PRIVACY POLICY, THE USER ACKNOWLEDGES AND AGREES WITH THE RISK OF DATA SECURITY BREACH AND THAT GUSMÃO & LABRUNIE SHALL NOT BE LIABLE FR ANY DATA SECURITY BREACH RESULTING FROM CYBERNETIC BREAKTHROUGHS CAUSED BY ACTIONS BEYOND ITS CONTROL AND THAT COULD NOT HAVE BEEN PREVENTED BY THE REASONABLE SAFETY, TECHNICAL AND ADMINISTRATIVE MEASURES ADOPTED BY GUSMÃO & LABRUNIE.

5. USERS’ RIGHTS

• The User may request, at any time, to Gusmão & Labrunie: () confirmation that his personal data is being processed; (I access to his personal data; (iii) correction of incomplete, inaccurate or outdated information; (iv) anonymization, blockade or deletion of unnecessary or excessive data, or data processed in disconformity with the provisions of the law; (v) portability of personal data to another service provider, provided that this does not affect industrial or trade secrets owned by Gusmão & Labrunie; (vi) deletion of personal data processed with his consent, to the extent permitted by the law; (vii) information on entities with which his personal data would have been shared; (viii) information on the possibility of not providing consent and consequences of such denial; and (ix) revocation of consent. Users’ requests shall be handled with special care and whenever there shall be no legal or regulatory impediment thereto. Gusmão & Labrunie may request that the User submit identity evidence upon exercising any of the rights listed herein.

• In the event that the User wished to exercise any of the rights listed herein or in the applicable Brazilian law, or to stop receiving Gusmão & Labrunie newsletters (opt-out), he may do so by means of the channel FALE CONOSCO or by sending an e-mail to para comunicacao@glpi.com.br.

6. EXTERNAL WEBSITES

• Users may eventually find in the Website links for external websites or restricted communications channels (“Access to Client”), which shall have their own policies, over which Gusmão & Labrunie has no control or influence whatsoever.

Gusmão & Labrunie does not agree with, accept, consent to, endorse, support, defend, corroborate, conform, approve or ratify any third party’s contents eventually indicated in the Website.

7. UPDATES AND MODIFICATIONS OF THIS POLICY

• The conditions specified in this Privacy Policy may be modified at any time. In the event that any such modification is significant or affects, in a concrete manner, the rights and obligations provided for herein, they shall be submitted to the User and, if applicable, his agreement will be requested.

8. MISCELLANEOUS PROVISIONS

• This Privacy Policy does not supersede, modifies or extends any other one also governing the User’s relationship with Gusmão & Labrunie.

• This Privacy Policy shall be governed by and construed in accordance with the laws of the Federative Republic of Brazil. The Central Courts of the Judicial District of the City of São Paulo, State of São Paulo are hereby elected to settle any controversy arising out of this Privacy Policy, whenever possible.

• If you have any doubt or suggestion regarding the conditions contained in the present Privacy Policy or the Website contents, please contact us through the channel FALE CONOSCO or e-mail us at comunicacao@glpi.com.br.

[1] Cookies are small texts used to store information in Web browsers. A cookie is sent to the user’s computer whenever he visits a website. When the user visits the website again, the cookie allows the site to recognize his browser. Cookies may store the user’s preferences and other information.