Data Protection Code

General Information

This document (“Declaration of Confidentiality”) provides detailed information on how Rayes & Fagundes Advogados Associados (“RFAA”, “we”, “our”, “with us” or “law firm”) handles personal data in the context of the respective activities. The provisions described in detail in this Declaration of Confidentiality are applicable to clients, potential clients, our website’s and social networks’ visitors, suppliers of products and services or any other individual who has or may have any commercial relationship with the law firm. In the event of doubts with respect to the provisions set forth in this Declaration of Confidentiality, or in the event you may want to access your personal information, for any reason, please contact RFAA by e-mail dados@rfaa.com.br.

Information on RFAA

For the purposes described in this Declaration of Confidentiality, RFAA must be identified as the agent responsible for the custody of the Personal Data submitted by Clients, Potential Clients and Suppliers of Products and Services (“Data Owners”). RFAA may be identified and contacted through the following channels:

1. Address: Av. Pres. Juscelino Kubitschek, 510 – 6o andar – Vila Nova Conceição
2. CNPJ: 02.678.067/0001-05
3. Email: dados@rfaa.com.br
4. Telephone: (11) 3050-2150

Personal Data Collection

In the context of the activities, RFAA may collect personal data when:

1. 1. provided directly by clients, potential clients, legal representatives and financial responsible persons, and employees (“Data Owners”);
   2. derived from browsing or voluntary interaction in your website and social networks, including the completion of the forms in section “Job Opportunities”;
   3. shared by outsourced service providers;
   4. disclosed to the public by the owner of the information; and/or
   5. publicly available.

Personal Data Category

Upon request of the personal data collection by RFAA and/or members and associates, the personal data handling must be limited to the following personal data categories:

• Identification Data: data that allows for the identification of the Data Owner who has any relationship with RFAA – clients, potential clients, legal representatives and financial responsible persons, and employees – including, for example: full name, birth date, nationality, profession, home address, e-mail, zip code and fixed and mobile telephones;
• Insight Personal Data: data relating to the data owner who has any relationship with RFAA – clients and potential clients – including: information relating to racial or ethnical origin, religious belief, political opinion, association with any trade union or religious, philosofical or political institution, health or sexual life data, genetic or biometric information of the individual;

ATTENTION: depending on the nature of the provision of the services, RFAA may collect insight personal data of clients and potential clients, for specific purposes, provided that previously informed and authorized, however the case may be:

• Financial data: data that allows for the collection or bank settlement, by RFAA, of the legal services provided, including, for example: CPF, bank information and other payment information.

Personal data handling

All personal data are handled by RFAA in accordance with the legal and regulatory provisions in force, specifically the provisions set forth in Law 13708/18 – General Data Protection Law, for the following purposes:

• Provision of legal services: RFAA handles the personal data voluntarily provided by the clients to perform the contracted legal sservices. In the provision of these services, RFAA may provide such information to third parties, such as technical assistants and other professional consultants, in order to represent the respective interests more efficiently. The personal data handling is necessary to perform the agreement entered into with the client.
• Management of the relationships with clients and suppliers: RFAA may handle personal data for purposes of updating the clients’ records and management of the commercial relationships with suppliers. Such handling is necessary to perform the agreement entered into with the client.
• Consultations/feedback of clients: we use identification data, contact information and other service information for this purpose. Such handling is necessary to perform the agreement entered into with the client. We may also need to use such information according to our own interests or to maintain the relationship with you; you may also be interested to receive a response from us after any contact.

Access to personal data

The access to personal data of clients, potential clients, legal representatives and financial responsible persons, and employees will be limited to the FRAA’s members and associates for the specific purpose of providing the legal services.

How do we preserve and protect the personal data under our custody?

RFAA adopts highly complex administrative, technical and physical measures to protect the personal data under its custody. These measures include information technology protection systems and safe files and facilities. In turn, after handling of such personal data, we adopt the proper measures to safetly exclude or permanently disconnect your personal data, under applicahle legislation in force.

We maintain your personal data solely during the term deemed necessary for the processing of your application or for purposes of information on future opportunities, except if any additional retention is required, in conformity with the provisions set forth in Law 13708/2018 – General Data Protection Law.

RFAA reserves the right to contract third parties – operators – to store the personal data, in which case these agents must handle the personal data according to the previous directions in writing determined by RFAA and ensure the confidentiality and security of such personal data.

Sharing of personal data with third parties

RFAA does not share Personal Data with any third party, except for the following events:

• with regulatory authorities, courts and governmental agencies to comply with legal orders, legal requirements or regulatory determinations and governmental requests;
• with Service Providers (“Operators”), regulatory authorities and government agencies to identify and prevent fraud or any other type of criminal activity, as well as to protect the RFAA’s or other rights;
• for purposes of credit protection;
• with Operators for performance of projects and development of businesses, as requested by RFAA.

In the event the personal data may need to be shared with third parties by means other than those described above, RFAA will inform the data owner to obtain the specific authorization for such purpose, except for the events provided for applicable legislation in force.

As referred to in the item above, RFAA reserves the right to store the personal data under its custody with the Operators contracted that may be or not established in Brazil. Upon personal data transfer to other jurisdictions, the recipients of such information must always be countries or international organizations qualified to provide the proper protection level, in conformity with Law 13708/2018 – General Data Protection Law.

Your Rights – in conformity with article 14 of the LGPD

In conformity with the LGPD, the Data Owners may define some conditions with respect to the handling of the respective personal data, including the following:

• Right to not provide your Personal Data, except for the fact that certain data is essential for the purpose defined in this Declaration of Confidentiality;
• Right to be informed with respect to the personal data handling;
• Right to access, correct and update the Personal Data;
• Right to request the exclusion of the personal data, except for those cases in which the Personal Data is essential for the activity performed by RFAA or in the event the storage of such Personal Data represents any legal, regulatory or contractual obligation, or for purposes of lawful exercise of the rights;
• Right to transfer the Personal Data to another controller; and
• Right to remove the authorization for the handling of the Personal Data, if applicable.

If you select any of the abovementioned actions, or in the event you may have any question with respect to the handling of your personal data, please contact the RFAA’s Responsible for the channels described in Item 1 of this Declaration of Confidentiality.

Changes in this Declaration of Confidentiality

RFAA reserves the right to change or modify this Declaration of Confidentiality at any time, including, but not limited to, legislative, regulatory and legal updates.
In the event of change in the terms referred to herein, RFAA will notify the data owners and describe in detail the changes.
In the event of any doubt, please contact us using the channels mentioned in Item 1 of this Declaration of Confidentiality.