Na Alehsi & Partners, privacy and security are priorities and we are committed to transparency in the processing of our users/clients' personal data. That's why we created thisPrivacy Policyto explain how the collection, use and transfer of information from our customers or other people who access or use our website is carried out under the Data Protection regulations (LGPD, Federal Law 13.709/2018), the consumerist provisions of Federal Law 8078/ 1990 and other applicable rules of the Brazilian legal system. Thus, Alehsi & Partners, registered under CNPJ nº 30.944.732/0001-09, in the role of Data Controller, undertakes to comply with the provisions of this Privacy Policy.

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1. What data do we collect about you and for what purpose?

Our website collects and uses some of your personal data, in order to enable the provision of services and improve your user experience.

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1.1. Personal data provided by the user in the “Contact” field of the website:

•  Email;

•  First and Last Name.

 

1.2. Purpose of data use:

•  Customer registration;

•  Sending monthly newsletters on company news and relevant content;

• Clarification of doubts;

• Telephone or electronic contact for business or technical purposes.

 

2. How do we collect your data?

Every user who registers on the site, through the “Contacts” page, either to receive news from theAlehsi & Partners, whether to send a message, is automatically inserted into our database of customers and/or interested parties.

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2.1. Consent:

When registering, you automatically consent to the insertion and use of your data. Consent is the free, informed and unambiguous manifestation by which you authorize theAlehsi & Partnersto treat your data. Thus, in line with the General Data Protection Law, your data will only be collected with our commitment to transparency and good faith following the relevant legislative regulations.

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When using the services ofAlehsi & Partners  and provide your personal data, you are aware of and consenting to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them. At any time and at no cost, you may withdraw your consent. It is important to highlight that the revocation of consent for the processing of data may imply the impossibility of the proper performance of some functionality of the website that depends on the operation. Such consequences will be informed in advance.

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3. What are your rights?

A Alehsi & Partnersguarantees its users/customers their rights as holders provided for in article 18 of the General Data Protection Law. This way, you can, free of charge and at any time:

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• Confirm the existence of data processing, in a simplified way or in a clear and complete format;

• Access your data, being able to request them in a readable copy in printed form or electronically, safe and reputable;

• Correct your data, when requesting its edition, correction or update;

• Limit your data when unnecessary, excessive or treated in violation of the legislation through anonymization, blocking or deletion;

• Delete your processed data based on your consent, except in cases provided for by law;

• Revoke your consent, disallowing the processing of your data;

• Inform yourself about the possibility of not giving your consent and the consequences of the refusal.

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4. How can you exercise your titleholder rights?

To exercise your titleholder rights, you must contact a Alehsi & Partners  via email: tanja.lehniger@alehsi.com

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In order to guarantee your correct identification as the holder of the personal data object of the request, it is possible that we request documents or other evidence that can prove your identity. In this case, you will be informed in advance.

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5. How and for how long will your data be stored?

Your personal data collected by Alehsi & Partnerswill be used and stored for the time necessary to provide the service or to achieve the purposes listed in this Privacy Policy, considering the rights of data subjects and controllers. In general, your data will be kept as long as the contractual relationship between you and a Alehsi & Partnersendure. At the end of the period of storage of personal data, these will be deleted from our databases or anonymized, except for the hypotheses legally provided for in article 16 general data protection law, namely:

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I – compliance with a legal or regulatory obligation by the controlling shareholder;

II – study by research body, ensuring, whenever possible, the anonymization of personal data;

III – transfer to a third party, provided that the data processing requirements set forth in this Law are respected; or

IV – exclusive use by the controller, access by a third party is prohibited, provided that the data is anonymised.

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That is, personal information about you that is essential for compliance with legal, judicial and administrative determinations and/or for the exercise of the right of defense in judicial and administrative proceedings will be maintained, despite the exclusion of other data._cc781905-5cde- 3194-bb3b-136bad5cf58d_

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The storage of data collected by Alehsi & Partners  reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions able to guarantee the confidentiality, integrity and inviolability of your data. In addition, we also have security measures appropriate to the risks and control access to stored information.

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6. What do we do to keep your data safe?

To keep your personal information safe, we use physical, electronic and managerial tools aimed at protecting your privacy. We apply these tools taking into account the nature of the personal data collected, the context and purpose of the treatment and the risks that possible violations would generate for the rights and freedoms of the holder of the data collected and processed.

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Among the measures we adopt, we highlight the following:

• Only authorized persons have access to your personal data;

• Access to your personal data is only done after the commitment of confidentiality and consent;

• Your personal data is stored in a safe and suitable environment.

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A Alehsi & Partnersundertakes to adopt the best postures to avoid security incidents. However, it is necessary to point out that no virtual page is entirely safe and risk-free. It is possible that, despite all our security protocols, problems that are solely the fault of third parties may occur, such as cyber attacks by hackers, or also as a result of negligence or imprudence by the user/customer. In case of security incidents that could generate risk or relevant damage for you or any of our users/customers, we will inform those affected and the National Data Protection Authority about what happened, in accordance with the provisions of the General Data Protection Law. Data.

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7. With whom may your data be shared?

In order to preserve your privacy, a Alehsi & Partnerswill not share your personal data with any unauthorized third party.  In addition, there are other situations in which your data may be shared, which are:

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I – Legal determination, application, requisition or court order, with competent judicial, administrative or governmental authorities;

II – Case of corporate movements, such as merger, acquisition and incorporation, automatically;

III – Protection of the rights of Alehsi & Partners in any type of conflict, including legal ones.

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7.1. International data transfer:

Some of the third parties with whom we share your data may be located or have facilities located in foreign countries. Under these conditions, in any case, your personal data will be subject to the General Data Protection Law and other Brazilian data protection legislation. , in the best efforts to ensure and comply with legislative requirements.

By agreeing to this Privacy Policy, you agree to this sharing, which will take place according to the purposes described in this instrument.

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8. Cookies or browsing data:

A Alehsi & Partners  makes use of Cookies, which are text files sent by the platform to your computer and stored there, which contain information related to website navigation. In short, Cookies are used to improve the user experience.

By accessing our website and consenting to the use of Cookies, you acknowledge and accept the use of a navigation data collection system with the use of Cookies on your device. Our website uses the following Cookies: 

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• XSRF-TOKEN – used to prevent CSRF requests;

• bSession – controls user access;

• hs - used for security reasons;

• ssr-caching - used to indicate the system the site was rendered from;

• svSession - Used in connection with user login.

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You can, at any time and at no cost, change permissions, block or refuse Cookies. However, the revocation of consent for certain Cookies may prevent the correct functioning of some platform features.

To manage your browser's cookies, just do it directly in the browser settings, in the Cookie management area. You can access tutorials on the topic directly from the links below:

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9. Amendment to this Privacy Policy:

The current version of the Privacy Policy was formulated and last updated on: (01.10.2021).

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We reserve the right to modify this Privacy Policy at any time, mainly in terms of adaptation to any changes made to our website or in the legislative field. We recommend that you review it frequently.

Any changes will come into effect as of their publication on our website and we will always notify you of any changes that have occurred.

By using our services and providing your personal data after such modifications, you consent to them. 

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10. Responsibility:

A Alehsi & Partners  provides for the responsibility of agents who work in data processing processes, in accordance with articles 42 to 45 of the General Data Protection Law. We are committed to keeping this Privacy Policy up to date, observing its provisions and ensuring compliance, we are also committed to seeking technical and organizational conditions that are safely able to protect the entire data processing process.

If the National Data Protection Authority requires the adoption of measures regarding the processing of data carried out by Alehsi & Partners, we undertake to follow them. 

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10.1 Disclaimer:

As mentioned in Topic 6, although we adopt high security standards to prevent incidents, no virtual page is entirely risk-free. In this sense, Alehsi & Partners is not responsible for:

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I – Any consequences arising from the negligence, imprudence or malpractice of users in relation to their individual data. We guarantee and are only responsible for the security of the data processing processes and the fulfillment of the purposes described in this instrument. We point out that the user is responsible for the confidentiality of access data;

II – Malicious actions by third parties, such as hacker attacks, unless proven culpable or deliberate conduct by Alehsi & Partners. We point out that in case of security incidents that may generate risk or relevant damage to you or any of our users/customers, we will inform those affected and the National Data Protection Authority about what happened and we will comply with the necessary measures;

III – Inaccuracy of the information entered by the user/client in the records necessary for the use of Alehsi & Partners services; any consequences arising from false information or information entered in bad faith are entirely the responsibility of the user/client.

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11. Data Protection Officer:

A Alehsi & Partners  provides the following means for you to contact us to exercise your title rights: tanja.lehniger@alehsi.com.

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If you have questions about this Privacy Policy or about the personal data we process, you can contact our Personal Data Protection Officer, via email: tanja.lehniger@alehsi.com.

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Tanja Catherine Lehniger

229,497,608-80

tanja.lehniger@alehsi.com