COMMITMENT TO PERSONAL DATA PROTECTIONNelson Wilians Advogados, NWADV, respects your privacy and is strongly committed to the protection of Personal Data and compliance with the requirements of the General Data Protection Act (Law No. 13,709/18).This Privacy and Personal Data Protection Policy informs how Nelson Wilians Advogados, a company registered with the CNPJ/MF under n. 03.584.647/0001-04, with head office located at Avenida das Nações Unidas No. 12.901, 17th floor, West Tower of the Centro Empresarial Nações Unidas, Brooklin, São Paulo/SP, CEP 04578-910, collects, processes and protects your Personal Data in the course of its activities, and also provides information on the rights of Data Subjects.At Nelson Wilians Advogados, we believe that data protection is the basis for relationships characterized by trust, good reputation and sustainability.
1. WHAT DO YOU NEED TO KNOW TO ENDORSE THIS POLICY?To facilitate the reading of this Policy, we provide some useful definitions for its complete understanding:We will use the terms “we”, “us” and “our” to refer to our team and any member of Nelson Wilians Advogados, which includes partners, associates, interns, business partners, employees and other members directly related to us.We will also use, “you”, “your” and “yours” and other similar terms to refer to our clients, individuals related to our clients, contacts, suppliers, business partners, job applicants, professionals on our team and visitors to the Nelson Wilians Advogados website.“Personal Data” is all information that allows you to be identified. For example: your name, CPF, e-mail, telephone number, among others.“Sensitive Personal Data” is information relating to racial or ethnic origin, religious belief, political opinion, membership of a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data when linked to you. This type of data is processed by Nelson Wilians Advogados only in limited and exceptional circumstances, for legal and regulatory purposes or upon your consent, for a specific, clearly informed purpose.“Data Subject” is the natural person to whom the Personal Data that is the subject of Processing by the NWADV relates.“Processing” is any activity performed with Personal Data, such as collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.“Controller” of Personal Data is the individual or legal entity, whether governed by public or private law, who is responsible for decisions concerning the Processing of Personal Data.“Operator” means the natural or legal person, whether governed by public or private law, who performs the Processing of Personal Data on behalf of the Controller.“National Data Protection Authority” (ANPD) is the public administration body responsible for overseeing, implementing and enforcing compliance with the General Data Protection Act, LGPD, (Law No. 13,709/18) throughout the national territory. https://www.gov.br/anpd/pt-br
2. WHAT KIND OF PERSONAL DATA DOES NWADV HANDLE?Nelson Wilians Advogados collects and processes only the Personal Data necessary for the performance of its activities, always respecting the limits permitted by applicable law and the privacy of the Data Subject.In this context, examples of Personal Data handled within the scope of its activities are:• Registration and contact dataname, address, telephone/cell phone, e-mail, data from identification documents generated by official agencies (RG, CPF, CNH, OAB, PIS/PASEP, CTPS, NIS, NIT, CEI, CNH, as applicable), date of birth, filiation, nationality, place of birth, marital status, age, gender, place of birth;• Professional Informationposition, area, company, business phone/cell phone, e-mail, business address, reference letter, work history;• Sensitive DataAdmission medical exam, periodic medical exam, resignation medical exam, information about limitation of locomotion, biometrics, among others;• Educationcourses, certifications, licenses, academic transcripts;• Bank/financial databank, branch, account, debt certificate, credits, loans, salary, income, among others;• Digital identification dataIP address, logical source port, date, time and time zone of access, access history pages visited on the NWADV website, among others;• Data from children and teenagersname, date of birth, among others.
3. FOR WHAT PURPOSES IS PERSONAL DATA USED? Nelson Wilians Advogados collects and processes your Personal Data with your consent, where applicable, or in order to comply with legal, regulatory, contractual or other obligations.In general, we process Personal Data, including but not limited to the following purposes:• Customer data is used to enable communication, manage all the steps involved in the relationship, and provide the contracted services;• Data provided by Clients is necessary to provide the legal services contracted in the various areas and specialties of Law;• Business partner data is required to enable business intermediation under the terms of the partnerships entered into;• Data from suppliers of goods and services is used to enable the contracts signed with the Office;• Our professionals’ data is required to carry out training, engagement actions, engagement actions, pro bono work, meetings, videoconferences or conference calls, among other institutional actions. In short, such data is processed to fulfill the contracts entered into, to comply with legal obligations, and to serve our legitimate interests;• Applicants’ data is collected to enable the selection process of new professionals;• Data from users of the NWADV website is collected to enable the use of our website or to allow contact with NWADV;• Data of third-party participants in webinars, events, and lectures is used as necessary for the conduct of the event and other purposes arising therefrom;• Sensitive data may be collected to comply with legal and regulatory obligations, and also to enable the procedures required for granting and maintaining benefits, to ensure easy access to office premises, among others;• Data from minors can be collected for engagement and endomarketing actions for the office professionals.
4. WHO IS THE DATA CONTROLLER?Nelson Wilians Advogados is the Controller of your Personal Data as we are responsible for making decisions regarding Treatment, always in strict compliance with the LGPD and other applicable regulations.
5. WITH WHOM DO WE SHARE YOUR DATA?Nelson Wilians Advogados will only share your Personal Data with your consent or upon permission or obligation under applicable law.In this context, the Personal Data processed in the scope of our activities may be shared or transferred to third parties, in Brazil or abroad, in the following situations:• Service providers contracted to act on behalf of the firm providing support for certain activities and operations, for example, software, IT system providers, cloud service providers, payroll and human resources related services, among others. Our service providers and Operators have a contractual obligation to safeguard any Personal Data that may be shared by Nelson Wilians Advogados;• Provision of information required by audits, administrative and judicial authorities;• Business partners and Subsidiaries of the firm, by virtue of collaborative relationships.In these cases, Nelson Wilians Advogados undertakes to adopt the necessary measures to protect Personal Data and share them in the strict proportion necessary for the fulfillment of the respective purpose or compliance with the respective specific order, as the case may be.
6. INTERNATIONAL DATA TRANSFERNelson Wilians Advogados uses the support of technological infrastructures that may be established outside Brazil, such as servers, cloud services, software, among others that may be owned or provided by third parties.In these cases, Nelson Wilians Advogados will only enter into contractual relationships with third party Operators that meet the highest security standards, at least at the same level of protection of Personal Data adequate under Brazilian law.
7. HOW DO WE PROTECT YOUR DATA?Nelson Wilians Advogados is committed to continuous improvement of its technical and organizational security measures to protect your Personal Data from inappropriate access, accidental or unlawful destruction, loss, alteration, communication or any form of inappropriate or unlawful Processing.However, while we adopt industry-compliant security practices and use our best efforts to protect your Personal Data, it should be noted that no processing of Personal Data is completely secure and fail-safe.If you have any questions regarding this Policy or requests about the Processing of your Personal Data, please contact our Data Officer directly at firstname.lastname@example.org.
8. HOW LONG DO WE STORE YOUR DATA?Nelson Wilians Advogados will store your Personal Data only for as long as is necessary to fulfill the purposes for which we collected it. This includes, for example, the purposes of meeting any legal, regulatory, accounting, reporting requirements, to perform legal work, for the regular exercise of rights in judicial, administrative, or arbitration proceedings; or for other purposes provided by the LGPD.In determining the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the purposes for which we process such data, and applicable legal requirements.During this period, Nelson Wilians Advogados will adopt the necessary measures to keep your Personal Data protected, in safe and controlled environments, in compliance with the legislation in force.
11. PERSONAL DATA SUBJECT’S RIGHTSThe General Personal Data Protection Act gives you certain rights with regard to the processing of Your personal data. They are:YOUR RIGHTS – CONFIRMATION AND ACCESSEXPLANATION – You have the right to be informed and to have access to your Personal Data processed by Nelson Wilians Advogados.YOUR RIGHTS – CORRECTIONEXPLANATION – You have the right to request that we correct your Personal Data if it is incomplete, inaccurate or out of date.YOUR RIGHTS – ANONYMIZATION, BLOCKIN OR DELETIONEXPLANATION – You may at any time request: a) anonymization of your Personal Data so that they can no longer be linked to you and thusare no longer personal data; b) blocking of your Personal Data that is not needed or processed in accordance with the law; and c) deletion of your Personal Data, unless such a request is against the firm’s retention obligations.YOUR RIGHTS – PORTABILITYEXPLANATION – You may request that Nelson Wilians Advogados transfer your Personal Data to another service provider designated by you, provided that such transfer does not breach the Firm’s intellectual property or trade secrets.YOUR RIGHTS – SHARING INFORMATIONEXPLANATION – You have the right to be informed, if any, about the public and private entities with which we share your Personal Data.YOUR RIGHTS – INFORMATION ABOUT THE POSSIBILITY OF NOT CONSENTINGEXPLANATION – You have the right to receive clear and complete information about the possibility and consequences of not providing consent to the collection or processing of your Personal Data, when requested by the Company. Your consent, when required, must be free and informed. Therefore, whenever we ask for your consent, you are free to withhold it. In such cases, it is possible that some services cannot be provided.YOUR RIGHTS – REVOCATION OF CONSENTEXPLANATION – You have the right to withdraw your consent to the processing of your Personal Data at any time.YOUR RIGHTS – OPOSITIONEXPLANATION – You have the right to challenge the Processing of Personal Data carried out in case of non-compliance with the provisions of the LGPD.It is important to note that there are certain circumstances that may restrict the exercise of some rights under the LGPD, such as when the provision of information may reveal a trade secret or in cases where there is a legal requirement that Nelson Wilians Advogados keep certain Personal Data. This includes the hypotheses of fulfilling tax, accounting, auditing obligations, defending the NWADV’s rights in court or out of court, among others.
12. HOW CAN YOU CONTACT US?If you have any questions regarding this Policy or requests to exercise your rights, you may contact our Officer directly at email@example.com. UPDATES TO THIS POLICYNelson Wilians Advogados reserves the right to change or adjust this Policy at any time, and it is up to you to check it, whenever possible, through this electronic address.