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Privacy Policy

SUMMARY

LAUTENSCHLAGER ROMEIRO AND IWAMIZU ADVOGADOS (“LRI ADVOGADOS”), law firm enrolled with the Legal Entities Taxpayers’ Registry (CNPJ/MF) under No. 08.755.204/0001-44, is committed to protecting confidential and personal information, including that of its employees, clients and third parties.

Recognizing and respecting the legitimate processing of personal data according to highest level of privacy regulation, LRI ADVOGADOS developed this Privacy Policy (“Policy”), that must be observed by all employees, clients and third parties.

LRI ADVOGADOS is committed to adopt all the necessary measures to safeguard and ensure the protection of personal data of all data subjects and in the occasion of collecting, processing and use of personal data all applicable regulations shall be respected.

LRI ADVOGADOS undertakes, furthermore, to adopt the necessary security, technical and administrative measures to protect personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication or any type of improper or unlawful processing.

Only authorized employees can access the LRI ADVOGADOS database. Access to personal information is restricted and ensured by good practices and strict compliance standards. LRI ADVOGADOS undertakes not to sell or transfer your information to third parties without prior consent according with applicable legislation.

I. INTRODUCTION

1.1 Applicable laws and regulations: This Policy is governed by the Brazilian General Data Protection Law nº 13,709/2018 (“LGPD”), in accordance with the Constitution of the Federative Republic of Brazil, set out in its Article 5, subsection ‘LXXII’; the Habeas Data Law (“Habeas Data”) nº 9,507/1997; and, finally, of the Internet Civil Landmark, law nº 12,965/2014 (hereinafter, collectively, “Applicable Regulations”).

1.2 Scope of application: This Policy is applicable to the personal data handled by LRI ADVOGADOS that are subject to processing operations.

1.3 Subject matter: The purpose of this Policy is to demonstrate compliance with the duties established in the LGPD, and to regulate the Processing of Personal Data procedures including, but not limited to, the collection, access, withholding and exclusion of such data by LRI ADVOGADOS.

1.4 Definitions: For the purposes of this Processing Policy, consistent with the LGPD, the following have the meaning as follows:

ANPD: National Data Protection Authority at the federal level, responsible for the surveillance, penalization and regulation of personal data protection matters.

II. RIGHTS AND DUTIES

2.1 Data Subject Rights: According to Article 18 of the LGPD, the personal data owner holds the following rights:

(a) Obtaining confirmation regarding the existence of processing.

(b) Free access to personal data that has been subject to processing.

(c) Rectification of incomplete, inaccurate, or outdated personal data.

(d) Anonymization, blocking, or deletion of unnecessary, excessive data or data processed in non-compliance with the provisions of the LGPD.

(e) Portability of personal data to another service or product provider, upon express request, in accordance with the regulations of the ANPD, while observing trade and industrial secrets.

(f) Deletion of personal data processed with the data subject’s consent, except in the cases provided for in Article 16 of the LGPD.

(g) Information about the public and private entities with which the controller has shared personal data.

(h) Information on the possibility of denying consent and the consequences of such denial.

2.2. Request for Rights Form: LRI ADVOGADOS has professionals trained to answer your questions and requests to exercise your rights. You may fill out our Request of Rights Form (“Form”).

2.2.1. Request of Rights Form Analysis: When we receive your request our privacy team shall analyze and answer you in two ways, stating that (a) is a lawful and legitimate request and must therefore be examined; or (b) your request has been denied and, for certain reasons, cannot be granted.

(i) Perhaps it will be necessary to request further information to confirm your identity and ensure that you may exercise your rights. This is a safety measure to warrant that the data will not be disclosed to anyone who lacks authorization to receive it.

(ii) If your request is accepted, we shall do our best to contact our suppliers and partners that may have access to your personal data to warrant correction, exclusion or any other applicable right.

2.2.3. Term for Answer: Upon receipt of your request, our team will respond to you within a period of up to fifteen (15) days. If clarifications or additional information regarding your request are required, we may send you inquiries to ensure that we can provide a satisfactory response. In such cases, the deadlines will be suspended until we receive your response.

2.2.4. Non-grant of the Request: If a request cannot be fulfilled, LRI ADVOGADOS is committed to providing an explanation of the reasons for the possible denial of your request.

III. PROCESSING OF PERSONAL DATA

3.1. The personal data provided shall be treated for rendering legal assistance services purpose and for any other need related to the operations of LRI ADVOGADOS, namely:

(a) conduct general opinion surveys regarding our services.

(b) handle goods and services provided by third parties for LRI ADVOGADOS.

(c) answer questions, requests or complaints placed by the personal data subjects and governmental authorities and share the personal data with any other authorities that under the applicable regulations are entitled to receive and treat the personal data.

(d) sending content through newsletters.

(e) sending institutional news.

(f) provide invitations, reminders and thanks for events.

(g) to register the history of the cases and demonstration of the services rendered, preserving the confidentiality between client and LRI ADVOGADOS.

(h) billing and charging related to attorney fees and expenses.

(i) register your personal data into the information systems of LRI ADVOGADOS and in its commercial and operational databanks.

(j) plan business activities of LRI ADVOGADOS.

(k) any other activity necessary for LRI ADVOGADOS to develop its corporate purposes.

3.2 Data Retention Period: the personal data under the control of LRI ADVOGADOS will be retained for the period necessary according to the purpose of the processing and/or for the time required to comply with a legal or contractual obligation, pursuant to Article 15 of the LGPD.

3.3. LRI ADVOGADOS adopts a data retention policy consistent with the applicable law.

IV. COOKIES POLICY

4.1. Cookies are small text files stored in your browser or device that allow recognition of your preferences. They help us prioritize your interests during your experience on our website. The information collected through cookies refers to your browser, your IP address, date, time, duration of visits, and accessed links, and can be divided as follows:

(a) Essentials: they allow our website to function, and their deactivation may harm your access experience.

(b) Performance: analysis based on statistical data, the performance of our website through user navigation, enabling us to correct any problems found.

(c) Functional: maximize access personalization, directing personalized content and remembering recent choices and preferences.

4.2. How disable cookies

You can disable cookies in your browser settings, by installing plug-ins available on the market or by using other technologies. However, disabling them may compromise the functionality and your experience on our website.

V. REVISIONS

5.1. We recommend that you periodically consult this Policy to follow any updates in its content.

VI. FINAL COMMENTS

6.1. If you have any questions about this Policy, how we process your personal data or have difficulty accessing the rights request form, please contact our Data Protection Office Vinicius Fonseca Soares at dpo@lrilaw.com.br.