The purpose of this Privacy and Data Protection Policy (“Policy”) is to inform and ensure full transparency to Data Subjects (“Subjects”) about the processing of personal data carried out by the law firm David Rechulski, Advogados (“Firm”).


Upon Law No. 13.709/2018 going into effect, enacting the General Personal Data Protection Law (“LGPD”), the Firm, thoroughly committed to strict compliance with the law in all of its activities, has reviewed and updated its privacy and data protection policy, as well as its professional routine and internal procedures, to ensure that legal services continue to be provided in absolute compliance with the new legal requirements.



I. CONCEPTS


The LGPD sets forth specific terms and definitions. The main concepts listed in the LGPD are provided below, as are those required for properly understanding this Policy.


a. Subject: An individual to whom the personal data to be processed are related.

b. Personal Data: Information related to an identified or identifiable individual.

c. Sensitive Personal Data: Any personal data concerning racial or ethnic origin, religious beliefs, political views, affiliation with any union or religious, philosophical or political organization, data related to health and sexual life, genetic or biometrical data, where related to an individual.

d. Processing: Every operation conducted with personal data, such as those involved in the collection, production, reception, classification, use, reproduction, transmission, distribution, handling, filing, storage, deletion, assessment or control of or access to information or any change therein or communication, transfer, broadcast or extraction thereof.

e. Data Protection Officer: The person in charge of acting as a liaison between the controller, the Subjects and the National Data Protection Authority (“ANPD”).

f. Controller: An individual or a government or private-sector entity charged with making decisions on the processing of personal dat

g. Processor: An individual or a government or private-sector entity processing personal data on a controller’s behalf.

h. Applicable Laws: All legislation in Brazil, including laws, regulations, orders, decrees or other legal guidelines providing for processing of personal data.

II. DATA PROCESSING

The Firm processes personal data as strictly necessary and appropriate for specific and established purposes.

The personal data processed by the Firm may arise from different forms of interaction with Subjects themselves or with third parties sharing data for specific and lawful purposes, always consistent with the legal event legitimizing the relevant processing.

When necessary to fulfill the scope of the legal services provided by the Firm, it will share personal data with third parties or governmental authorities. In specific situations and for lawful purposes, the Firm will also share personal data with companies specializing in the business of analyzing and categorizing law firms.

The personal data processed by the Firm are name, photo ID (RG), taxpayer number (CPF), e-mail address, street address, telephone numbers, occupation and related institution and/or company. Other data may be equally processed by the Firm when necessary for any other specific purpose related to its legal services or for lawful purposes.

This Firm uses the website www.dreadv.com.br as its sole and exclusive official electronic address. The Firm’s providers may collect data through the cookies’ system to browsing and to meet legal obligations related to maintenance of records, especially those required by Law No. 12.965/2014 (“Civil Regulatory Framework for the Internet “), as well as standard internet login information for purposes of generating anonymous statistics.

Subjects and/or anyone who shared their data with the Firm are exclusively responsible for the truthfulness of the data provided. Accordingly, if any personal data is internalized at the Firm upon being shared by a third party for a specific purpose, then responsibility for the truthfulness of those data and the lawfulness of their collection lies exclusively with the thirdparty who has shared it.

In no event does the Firm buy or trades personal data and/or personal databases.

III.PERSONAL DATA PROCESSING PURPOSES


The Firm processes personal data primarily for the following purposes:

a. Contract drafting, reviewing or negotiation.

b. Providing legal services.

c. External audit.

d. Adding contents to the Firm’s activities and portfolio/website.

e. Disclosing legal and/or market contents, as well as events organized by and/or held with the participation of any member of David Rechulski, Advogados.

f. Registering Subjects on the mailing list.

g. Promoting institutional newsletters.

h. Registering suppliers/partners.

i. Storing resumés for recruitment of professionals and/or interns.

j. Preserving rights and performing obligations related to any lawful interests of David
Rechulski, Advogados

When processing personal data, the Firm will always respect the rights of Subjects and the guiding principles of the applicable laws, with due regard for the legal hypotheses highlighted below:


a. Consent from the Subject.

b. Compliance with legal or regulatory obligations.

c. Performance of contracts or contract-related preliminary procedures.

d. Ordinary exercise of rights in legal, administrative or arbitration proceedings.

e. Protecting the life or physical integrity of any Subject or third party.

f. Serving the Firm’s lawful interests.

IV.USERS’ RIGHTS


David Rechulski, Advogados ensures all Subjects have unrestricted and facilitated access to their rights under the applicable laws by making the communication channels indicated in this Policy available to make sure Subjects are able to effectively preserve those rights.

Data Subjects are ensured the right:


a. to confirmation of existence of data processing;

b. to access the personal data processed;

c. to correct any inaccurate, outdated or incorrect personal data;

d. to anonymization, blocking or deletion of unnecessary data;

e. to portability of personal data to other providers upon explicit request;

f. to deletion of any personal information processed with consent, except in the events set forth in the applicable laws;

g. to information on sharing personal data with any government or private-sector entities;

h. to be informed of the possibility of withholding consent and the consequences thereof;

i. to revoke consent;

j. to petition the National Authority

V. LENGTH OF DATA PROCESSING


David Rechulski, Advogados processes personal data with absolute caution, with total respect for information security, and for the period of time needed to fulfill the purpose legitimizing the relevant processing, and to meet legal and/or court requirements, always in compliance with the applicable laws, including, but not limited to, the General Personal Data Protection Law and the Civil Regulatory Framework for the Internet.

VI.SECURITY

The Firm is fully committed to the security of its personal data processing, and, in the conduct of its business, implements, maintains and constantly updates its information technology systems and its technical, physical and logical security procedures, using commercially available solutions, and following the best practices and guidelines issued by regulatory authorities.

Always with best practices in mind, the Firm emphasizes to Subjects the need for them to take preventive security measures designed to protect their data, including the use of antivirus software on their devices, personal passwords and other technical and management measures aimed at averting failures, invasions, personal data security incidents or other disturbances.

VII. COMMUNICATION CHANNEL

To make all of its personal data processing possible and to comply with this Policy, the Firm makes the contact information of its Data Protection Officer available:
E-mail: encarregado@dreadv.com.br

Address: Av. Dr. Chucri Zaidan, 1.550, Conjuntos 2906-2909, CEP 04711-130 Chácara Santo Antônio, São Paulo, São Paulo (Brazil)
Any complaints or notices from Subjects should be sent to the e-mail address indicated above.

The Data Protection Officer has been duly appointed by David Rechulski, Advogados to answer questions and/or take any steps related to the Firm’s processing of personal data in accordance with the General Personal Data Protection Law.

VIII. AMENDMENTS TO THIS POLICY

This Policy may be amended at any time by notice posted on the Firm’s institutional website at www.dreadv.com.br.


São Paulo, July 09, 2021.
David Rechulski, Advogado

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