PRIVACY POLICY

Latest version: February 14, 2019

GUSMÃO & LABRUNIE ADVOGADOS (“Gusmão & Labrunie”), a company registered under CNPJ/MF No. 03.415.856/0001-16 and headquartered at Avenida Brigadeiro Faria Lima, No. 1485, 11th floor, Jardim Paulistano, São Paulo/SP, CEP 01452-002 – Brazil, respects the norms regarding the protection of privacy and personal data and, therefore, has developed the present Privacy Policy, which provides for the treatment of the personal data of those who access its website www.glpi.com.br (“Website”).

For the purposes of this Policy, the term “User(s)” refers to any and all individuals browsing the Gusmão & Labrunie Website and/or accessing any of the features available thereunder not regulated by any other specific Privacy Policy.

  1. DATA COLLECTED AND PURPOSE OF COLLECTION
  • User data, including personal information, may be collected from the user’s interaction with the Website, in particular to enable (i) the User’s appropriate contact with Gusmão & Labrunie and (ii) newsletter submission, as well as (iii) to ensure navigation in restricted areas such as “Client Area”, which will only be performed by means of login and password and is governed by its own rules.
  • The data collection by Gusmão & Labrunie is done as follows:
  • Information provided directly by the User: Gusmão & Labrunie collects personal data provided directly by the User to, for example, complete the online forms for contact and newsletter submission, which may include: (i) name; (ii) job role; (iii) company or entity to which it relates; and (iv) contact information, including email and telephone number.
  • Information collected automatically: When the User visits the Website, Gusmão & Labrunie may automatically collect information such as (i) IP address; (ii) device identification (ID or IMEI code, for example); (iii) browser type and language; (iv) data on click stream on the Website; (v) time of access and interaction with the Website; and (vi) other data collected automatically, such as those obtained through cookies (as set forth in item 3 of this Privacy Policy).

Such information allows Gusmão & Labrunie to better understand its Users, where they are located and what content of the Website is of their interest and, therefore, are used for analytical purposes and to improve the quality and relevance of the Website.

  • Other information: Gusmão & Labrunie will also collect information that the User provides in their communication and/or interaction (such as when the “like” option is selected, for example) with Gusmão & Labrunie through social networks, or the partner recruitment and selection agencies of Gusmão & Labrunie when applying for one of our job vacancies, these being used only for the purpose of recruitment and selection of candidates.
  • Other information may also be collected for the purpose of complying with binding laws and regulations of public administration, as well as the legitimate interest of Gusmão & Labrunie.
  1. LEGAL BASES FOR TREATMENT AND DATA SHARING

 

  • The legal basis for collecting and using the above personal information depends on the kind of personal data in question and the context of the collection. However, Gusmão & Labrunie normally collects personal data when it has the consent of its User, when such data is necessary to execute a contract with the User, or when the processing of personal data is performed based on the legitimate interests of Gusmão & Labrunie. In some cases, Gusmão & Labrunie may have a legal obligation to treat certain personal data or to defend itself administratively and judicially.
  • The information collected by Gusmão & Labrunie may be shared as follows:
  • Gusmão & Labrunie may share the information collected with any person authorized by the User.
  • Gusmão & Labrunie may share the information collected from the User with police or judicial authorities, competent public authorities or other third parties, if required by applicable law.
  • In the case of corporate transactions, such as restructuring, merger or sale of Gusmão & Labrunie, the data collected may be transferred, provided that the terms of this Privacy Policy are respected. The same may occur in cases of judicial recovery or bankruptcy.
  • The User acknowledges and authorizes that the aggregated and anonymous information may be freely shared by Gusmão & Labrunie.
  1. COOKIES
  • Gusmão & Labrunie uses cookies [1]to allow the operation of certain aspects of the Website and does not store any data that can directly identify the User. Also, Gusmão & Labrunie uses cookies that allow to verify the number of visits, traffic and interaction in the Website. These cookies are used to generate aggregated data and anonymous analytical reports.
  • The User will be able to manage preferences of cookies and other technologies from the configuration of his navigator or device, but depending on the choices this will prevent certain aspects of the Website from working.
  1. STORAGE AND SECURITY OF DATA
  • Gusmão & Labrunie takes precautions, including administrative, technical and physical measures compatible with the state of the art and its economic size and activities, to protect your personal information against loss, theft, misuse, as well as against unauthorized access, disclosure, alteration and destruction.
  • The professionals from Gusmão & Labrunie who have contact with the information collected are subject to specific confidentiality rules and other policies applicable by Gusmão & Labrunie to their associates, employees and partners.
  • Gusmão & Labrunie does not have any responsibility for the quality of the connection used by the Users to access the Website.
  • Gusmão & Labrunie keeps the personal information of the Users stored for the time necessary to achieve the purposes described in this Privacy Policy, taking into account any duty of retention of information that is prescribed by law.
  • The User may request the deletion of the personal information provided to Gusmão & Labrunie. If the exclusion is requested, your information will be permanently deleted, whenever required by law. In some cases, however, the information may be withheld, such as for the purposes of compliance with contractual obligations, use in dispute resolution and/or other permitted or lawful reasons.
  • BY CONSENTING WITH THIS PRIVACY POLICY, THE USER AGREE TO THE DATA LEAKAGE RISK AND THAT GUSMÃO & LABRUNIE SHALL NOT BE LIABLE FOR ANY LEAKS OF DATA ARISING FROM CYBER-INVASION CAUSED BY ACTIONS OUTSIDE OF ITS CONTROL AND WHICH COULD NOT BE PREVENTED WITH THE REASONABLE SAFETY, TECHNICAL AND ADMINISTRATIVE MEASURES ADOPTED BY GUSMÃO & LABRUNIE.
  1. USERS RIGHTS
  • The User may request, at any time, from Gusmão & Labrunie: (i) confirmation that his/her personal data is being processed; (ii) access to its personal data; (iii) corrections to incomplete, inaccurate or outdated data; (iv) anonymization, blocking or elimination of unnecessary, excessive or treated data not in accordance with the provisions of the law; (v) portability of personal data to another service provider, provided that this does not affect the industrial and commercial secrets of Gusmão & Labrunie; (v) deletion of personal data processed with your consent, to the extent permitted by law; (vi) information on the entities with which your personal data have been shared; (viii) information about the possibility of not providing consent and the consequences of refusal; and (ix) withdrawal of consent. Users’ requests will be treated with special care and whenever there is no legal or regulatory impediment. Gusmão & Labrunie may request that the User prove his/her identity when exercising the rights listed herein.
  • In the event that the User wishes to exercise any of the rights listed here, those provided for in applicable Brazilian law or to stop receiving Gusmão & Labrunie (opt-out) newsletter, he/she may do so through the CONTACT US channel [generate hyperlink for contact form] or by sending an e-mail to comunicacao@glpi.com.br.
  1. EXTERNAL WEBSITES
  • Users may, eventually, find on the Website links to external websites or restricted communication channels (“Customer Access”), which will have their own policies, without any control or interference by Gusmão & Labrunie.
  • Gusmão & Labrunie does not agree, accept, consents, endorse, defend, corroborates, confirm, approve or reaffirm the content of third parties that may eventually be indicated on the Website.
  1. UPDATES AND MODIFICATIONS OF THIS POLICY
  • The conditions specified in this Privacy Policy may be modified at any time. If the modifications are significant or affect, in concrete form, the rights and duties herein provided, they will be presented to the User, and, if appropriate, their agreement will be requested.
  1. GENERAL PROVISIONS
  • This Privacy Policy does not replace, modify or extend any other that may also govern the User’s relationship with Gusmão & Labrunie.
  • The present Privacy Policy shall be interpreted and governed in accordance with the laws of the Federative Republic of Brazil. The Central Forum of the District of the City of São Paulo, State of São Paulo, is hereby elected to resolve any conflict arising from this Privacy Policy, whenever possible.
  • In case of doubts and suggestions regarding the conditions contained in the present Privacy Policy or content of the Website, please contact us through the CONTACT US channel [generate hyperlink to contact form] or by sending an e-mail to comunicacao@glpi.com.br.

 

[1] Cookies are short snippets of text used to store information in web browsers. A cookie is sent to the user’s computer when he visits a website. When the user views the website again, the cookie allows the website to recognize the browser. Cookies can store user preferences and other information.