Privacy Policy

The law firm Sannazzaro Hira Campos Advogados, a company registered under the CNPJ n. 12.585.521/0001-37, located at Avenida Nove de Julho, n. 4877, 11th floor, Jardins, São Paulo/SP, ZIP Code 01407-200 (the “SHC” or “Firm”), committed to respecting the privacy, and protecting the personal data provided by its clients, business partners, employees and third parties, edits this Privacy Policy (the “Policy”) in compliance with applicable law in Brazil, in particular Law 13.709/2018 (“LGPD”).

SHC is committed to promoting a privacy and data protection corporate culture, respecting the trust placed on us by individuals when providing the Firm with their Personal Data.

The purpose of this Policy is to help the Data Subjects understand how and for what purpose SHC may process their Personal Data.

This Policy will be published and broadcasted through the website www.shc.adv.br and, eventually, attached as an integral part of contracts and agreements executed by the Firm.

Please read this Privacy Policy carefully to become aware of how and for what purpose your Personal Data may be treated by SHC. It is important that this Privacy Policy be interpreted together and in accordance with any other document, contract or privacy clause that accompanies it and without prejudice to the professional secrecy applicable to SHC’s relationship with its clients, in the form of the Code of Ethics and Discipline of the Brazilian Bar Association.

If, after reading this Policy, you still have any questions or, for any reason, need to get in touch with SHC regarding your Personal Data, you may contact the designated Data Protection Officer (the “DPO”):

Renato Vianna Sannazzaro
Avenida Nove de Julho, n. 4877, 11th floor, Jardins, São Paulo/SP, ZIP Code 01407-200
Mobile phone: +55 (11) 98617-4204
E-mail: rvs@shc.adv.br

1. Definitions

For a better comprehension of this Policy, the following definitions should be considered, which can be read in plural or singular:

Personal Data: any information or data related to an identified or identifiable individual.
Subject or Data Subject: individual to whom the Personal Data that are subject to Treatment refer.
Treatment: access, collection, use, processing, storage, sharing, distribution, transfer, disclosure, security, destruction, or disposal of any personal, sensitive, or confidential information or data
Operators: third parties with which SHC may share the Personal Data collected for the purpose of operating its services.
Website: the SHC’s website, https://www.shc.adv.br/

2. Controller

The SHC will assume the position of data Controller when it is responsible for decisions regarding the Treatment of Personal Data within the scope of the relationship established with the Subject, in compliance with LGPD, other applicable laws and this Policy.

3. Data Subjects

This Policy applies to:

Clients: all those who have maintained or maintain a legal relationship with the SHC and individuals linked to these Clients.
Web Users: all those who access the Website, those who register and request information through the Website and/or those who subscribe to our newsletter.
Third Parties: those who visits the Firm’s physical facilities and do not qualify as Clients, Commercial Partners or Collaborators of SHC.
Collaborators: all those who were or are collaborators of the SHC and their dependents, as well as candidates, partners and associates of the Firm.
Commercial Partners: all people who have maintained or maintain a commercial relationship with SHC and individuals linked to these Commercial Partners, that is, their employees, partners and shareholders.

3.1. Subjects Web Users

The registration of companies on the Website must necessarily be carried out by a duly authorized legal representative.

SHC does not collect or knowingly request Personal Data from minors through its Website. Web users under the age of 18 should not send Personal Data through the Website. Upon learning of the collection of Personal Data from an individual under the age of 18 through its Website, SHC will disregard the information provided and will not keep it in its database.

4. Which are the Personal Data Treated

SHC may collect and process Personal Data in the following categories:

Identification data (name, RG, CPF, date of birth, gender, area of interest, language for correspondence, nationality, passport, voter registration, education, profession, date of birth, marital status, signature, photos, videos, between others);
Contact data (e-mail, business address, home address, cell phone, social profiles);
Sensitive data (personal data that reveal the Subject’s racial or ethnic origin, biometric data, data related to the Subject’s health and other data that may be provided within the scope of the contractual relationship established between the Customer and SHC, in the context of the provision of contracted legal services);
Financial data (bank account number, name on credit/debit card, transaction log, etc.); It is
Behavioral and digital identification data (IP address, cookies, activity log, location data, Website pages accessed, origin of access, device information, etc.).

When contracting our legal services, we will ask our clients for the necessary information, which may include identification data, contact data, sensitive data, financial data, and other relevant information. In addition, it may be necessary to collect and process personal data from third parties related to our customers (for example, family members’ data), which may be relevant to the provision of our services.

5. Internet Browsing Data

When accessing the Website, to facilitate and personalize the Web User experience, cookies are stored on the access device. The Web User is free to refuse the cookies of the Website if the browser used allows it, but some parts of the site may not work correctly in this case. Thus, we collect information about the access of the Web User and how he interacts with our Website.

5.1. What are Cookies and How are they used?

A cookie is a small data text file that a website can store on the hard disk of the access device used by the Web User, depending on the browser settings, and retrieve it later for identification purposes. Cookies make the Website easier to use and help keep it secure.

Device Information: in order to comply with the legal obligation of the Marco Civil da Internet (art. 15), SHC may collect information about the devices used to access the Website, namely the IP, date and time of access. It is important to mention that Personal Data is not collected through cookies, pixels or other similar tools. The use of cookies by the Website is restricted to statistical analyzes regarding the use of the Website, without any link to the IP or other Personal Data of the Web User.

5.2. Third Party Site Privacy Policies

As for the treatment of Web Users’ data, this document relates only to the use and disclosure of information collected through the Website. Other websites accessible through the Website have their own privacy policies and disclosure practices. SHC is not responsible for the policies or practices of third parties.

6. How Personal Data is stored

SHC stores your Personal Data securely in its internal system, adopting – within its possibilities and responsibilities – the best technical and administrative practices to protect Personal Data from unauthorized access, destruction, loss, alteration, disclosure or any form of inappropriate or unlawful treatment.

Still, no platform is completely secure. If you have any concerns or suspicions that your Personal Data is at risk, for example if you become aware of unauthorized access to your Personal Data, please contact the Firm immediately.

In the event of a breach of data under the custody of SHC, the Firm guarantees full efforts to remedy the consequences of the event.

7. Purpose of Personal Data Treatment

The Treatment of all Personal Data collected is intended to enable and/or improve the provision of legal services for which SHC is contracted, as well as:

Identify and/or offer relevant content about a certain preference and/or interest expressed by the Subject to the SHC, including, but not limited to, newsletters, invitations to events, reminders, thank you notes, among others;
Carry out relationship campaigns with Customers and potential customers;
Offer legal services of interest to Web Users and Third Parties;
Fulfill and/or enforce contracts, procedures and any other demand requested by a Client to SHC;
Maintain security and physical access control to office premises;
Compose a database of SHC commercial partners and service providers;
Registration of commercial partners and service providers and execution of related contracts;
Compose a database of Collaborators, committees and other groups;
Forming a database of candidates for jobs, internships and services at SHC;
Exercise the protection, defense and administration of the interests of the SHC; It is
Comply with applicable law.

8. Legal Basis for the Treatment of Personal Data

The Processing of Personal Data can be carried out by SHC with the consent of its Subject, by legal, regulatory, contractual obligation and in accordance with the legal bases established by the LGPD.

Whenever necessary, SHC may ask the Subject to provide his consent in writing or by any other means that confirms such consent.

The Subject may withdraw his consent at any time by sending a formal request to the e-mail address of the Person in Charge.

8.1. Legal basis on the collection of Personal Data of Web Users

The LGPD establishes several situations in which the treatment of Personal Data is allowed regardless of the consent of its Subject. These are the so-called “legal bases for data processing”. This means that, by choosing to use the Website and with legal grounds for doing so, SHC may collect and process Personal Data regardless of the Owner’s consent.

Currently, on its Website, SHC collects, through this Policy, consent only for the treatment related to the registration by the Subject in the Firm’s newsletter and response to direct contact made through the Website. If there is any change in the processing of Personal Data that makes it necessary to collect consent, this Policy will be updated so that the Subject is informed, and consent is duly collected under the terms of the LGPD.

9. Sharing of Personal Data

SHC does not sell Personal Data. Eventually, SHC may share Personal Data with third parties for the purpose of operating the contracted legal services.

The Operators with whom SHC shares Personal Data will always process them on behalf of and in accordance with the Firm’s instructions, meeting the purposes set out in this Policy.

Among the possible Operators, technology service providers and physical space security service providers stand out, as well as Commercial Partners with which SHC maintains a collaborative relationship to provide services and also Collaborators.

SHC may share Personal Data with judicial, police, governmental authorities or third parties with whom the Firm is required by law or executive/court order to share Personal Data.

In all cases, SHC undertakes to strictly share the Personal Data that may be necessary to fulfill the respective purpose or comply with the respective specific order.

9.1. International Transfer of Personal Data

SHC uses cloud storage systems, for this reason it is possible that Personal Data is transferred outside of Brazil, since the technology service providers contracted by the Office can host their systems in other countries.

In these cases, the Firm ensures only contracting third parties that meet the highest security standards in the protection of Personal Data, in line with Brazilian legislation.

10. For how long processing and storage of Personal Data last

SHC may store Your Personal Data for the time necessary to fulfill the purposes mentioned in this Policy, as well as to comply with a legal or regulatory obligation, as well as for the regular exercise of rights in judicial, administrative or arbitration proceedings, or for other purposes provided for in the LGPD, such as, for example, for its exclusive use, anonymously or in situations that justify its legitimate interest.

It is important to point out that, even after the end of services, some records must remain accessible by legal imposition or may be necessary to demonstrate the terms of the relationship (applicable statute of limitations), penalties being used for these purposes.

Personal Data may be kept anonymously, that is, without being related to its Subject, for longer periods.

11. Subject’s Rights

Under the terms of the LGPD, the Subject is entitled to:

Confirmation of processing of your Personal Data by SHC.
Access to your Personal Data.
Correction of incomplete, inaccurate, or outdated Personal Data.
Anonymization, blocking or deletion of Personal Data that is unnecessary, excessive or processed in violation of the provisions of the LGPD.
Portability of your Personal Data to another service or product provider, observing SHC’s commercial and industrial secrets, after regulation by the National Data Protection Authority.
Elimination of Personal Data processed based on your consent, except in the cases of Personal Data conservation provided for in the LGPD.
Obtaining information about who your Personal Data is shared with.
Obtaining information about the possibility of not providing your consent and the consequences.
Revocation of your consent to the processing of your Personal Data, when based on your consent.
Opposition to Treatment that violates the LGPD.

The Subject may exercise any of the above rights by sending an email to the DPO.

Before responding to any request to exercise these rights, SHC may request some information to confirm the identity of the Subject.

12. Review and Approval of this Policy

The Firm reserves the right, at any time, to change, modify, or even replace this Policy, always obeying the approval cycle of the areas and levels involved.

The most recent version of this Policy will be duly published on the Website when it is updated.

The Subject must check the updated version of this Policy every time he visits the Website.

In cases where the changes in this Policy imply changes in the processing practices of Personal Data that depend on the consent of the Subjects, the Subjects will be asked to consent to the new terms of this Policy after the amendment so that they can continue using the Website and the services of the SHC.

Date of publication of this Privacy Policy on the Website: august, 2023.