Azevedo Prado will have access to personal data in the following situations:

• By means of interaction with a client: When the Client provides and imputes personal data necessary for the provision of services and use of products provided by Azevedo Prado.
• Interaction with its employees: When its employees and collaborators of any kind or nature use its systems and platforms to fulfill the duties and obligations arising from the contractual relationship they have.

Without prejudice to the data commonly collected and processed from its employees for the purposes of the legal relationship they have, Azevedo Prado may still collect the following personal data:

• Names and contact data, such as first and last name, email address, postal address, telephone number and other similar types of contact data, such as bank details;
• Device information, such as information about your device, IP address, location or provider;
• Usage information and browsing history, such as information about how the User navigates within our services, their browsing history and which elements of the Azevedo Prado a services are most used;

Sensitive personal data that may be collected by Azevedo Prado will have its purpose informed separately to the User, who must consent for the firm to use them in a specific way, and in case of disagreement, the data will be automatically deleted from the bases of the Azevedo Prado.

Azevedo Prado does not collect data from underage, except with the authorization of parents or an adult responsible, if they are collected without authorization, as soon as Azevedo Prado becomes aware, it will immediately delete the data collected, in accordance with the rules of the Terms of Use and this Privacy Policy.

When collected, Azevedo Prado will use personal data to:

• Provide and improve contracted services;
• Comply with a legal or regulatory obligation;
• Manage the relationship with Users;
• Configure and manage User accounts;
• Provide technical assistance, support and training to the User;
• Contact Users;
• Internal research and development purposes and to improve, test and refine the resources and functions of the services of Azevedo Prado.
• Provide Users with marketing, publicity, advertising, including from Partner companies of Azevedo Prado, as permitted by law;
• Meet internal and external audit requirements, including information security obligations of Azevedo Prado;
• Send email messages to: a) carry out confirmations or cancellations of requests by using the platform; b) communicate future changes that this policy may undergo; and c) disclose updates, changes, additions of new data sources and improvements to the platform.
• To exercise the rights of Azevedo Prado, including, but not limited to, the privacy, security, networks, systems and properties of Azevedo Prado and/or third parties; 
• Comply with requests from courts, police authorities, regulatory bodies and other public institutions and government authorities, including, but not limited to, any rules in force outside the user's country of residence;
• The exercise of the rights of Azevedo Prado and to defend against any lawsuits, as well as for compliance with any legislation or regulation applicable to Azevedo Prado or third parties with whom we work, as well as for the exercise of good compliance of contracts signed between Azevedo Prado and its users.

The User accepts and agrees that Azevedo Prado shares their personal data with the following recipient categories:

• Companies that provide access or are responsible for the registration on which the user is dependent; 
• Partner companies, such as third-party service providers and other companies that assist us in offering our services or that can take action on our behalf, protecting our rights, users, systems and services;
• Third parties to whom Azevedo Prado must give explanation for or is authorized to disclose information by law (Example: government bodies, regulatory agencies, judicial branch and other public authorities);
• Third parties in order to participate in the sale, consolidation, acquisition, restructuring, joint venture, assignment, transfer of part or all of Azevedo Prado business, in which case the User's data will be considered an asset and transferred in an eventual negotiation;
• Third parties who need the data to protect the rights of Azevedo Prado;
• Any individual or legal entity to whom the User requests the portability of their data.

Azevedo Prado does not intend to carry out the transfer of any personal data of the User captured outside Brazil, being certain that in case of inexistence of any event listed below, the Users will be informed in advance by e-mail, at which time the user may accept or not the transfer, and in case of disagreement, may have their access rights prevented by Azevedo Prado.

The cross-border processing described in the Brazilian General Data Protection Law (LGPD) lacks the designation of guidelines to be established by the Brazilian Data Protection Authority (ANPD), whereas, when defined, Azevedo Prado will undertake to comply with them in their entirety.

Azevedo Prado uses adequate technologies and procedures to protect any personal data collected (including administrative, technical and physical protections) according to the level of risk and the service provided, having a legally responsible team to deal with the safe management of the data in line with legal provisions, regulatory requirements, changes in technology, among other relevant factors that may influence the way to protect personal data.

Azevedo Prado employs all reasonable market efforts to ensure the security of its systems and the data collected, using highly qualified and reputable Internet providers and database and storage servers, in addition to security certificates (SSL) and software to protect against unauthorized access to the systems, as well as standard methods for encrypting and anonymizing the collected data.

This Policy represents the effort of Azevedo Prado to safeguard User information. However, due to the very nature of the Internet, it is not possible to guarantee that malicious third parties will not succeed in improperly accessing the stored information, which is why, in the event that this occurs, Azevedo Prado will be responsible within the limits provided for by Law.

Azevedo Prado, within a reasonable period to be defined by the Brazilian Data Protection Authority (“ANPD”), shall notify the ANPD and the affected User of the occurrence of a security incident that may entail significant risk or damage to the affected User, mentioning, at least:

• description of the nature of the personal data affected;
• information about the data holders involved;
• indication of the technical and security measures used to protect the data, with due regard for trade and industrial secrets;
• the risks related to the incident;
• the reasons for the delay, if the communication is not immediate; and
• measures which were or will be adopted to revert or mitigate the effects of the damage.

Azevedo Prado will be responsible for the processing as follows:

• When dealing with personal data provided directly by its Clients, Azevedo Prado will be the Operator, and will act without interference in the form of processing indicated by the Controller, but under the terms of the Brazilian General Data Protection (LGPD);
• Azevedo Prado will be the Controller of the Personal Data of its employees, treating them based on the Execution of Contracts, Compliance with legal or regulatory obligations, and also, in specific and determined situations, on Consent. 

Azevedo Prado may adopt different legal bases for different processing of personal data.

Azevedo Prado calculates the retention period of personal data according to the following criteria:

• Period necessary to fulfill the purpose of the collection;
• The moment when the Client/User stops using the services of Azevedo Prado;
• The moment when consent is revoked or request for deletion of personal data by the Holder;
• The time required to demonstrate compliance with the duties and obligations of Azevedo Prado;
• The necessary period provided for by law, regulations, court decisions, etc.;
• Determination of the Data Protection National Authority (ANPD);
• Compliance with legal or regulatory obligation by the Controller;
• Perfect execution of the contract;
• Needs related to compliance with the legal system, as well as for any legal disputes;
• Transfer to third parties, provided that the data processing requirements established in the law are respected; or
• For exclusive use by the controller, with any access by a third party forbidden, and provided that the data is anonymized.

Pursuant to the Brazilian General Data Protection Law (LGPD), User will have the following rights regarding the processing of their personal data:

• Confirmation Right: User will be able to confirm whether Azevedo Prado processes any of his/her personal data;
• Access Right; User may make a written request for details of how their information is being used, as well as a copy of said information;
• Correction Right: User may correct or remove any data that is incomplete, inaccurate or out of date;
• Anonymization, blocking or deletion Right: User may request the anonymization, temporary limitation or deletion of data that is unnecessary, excessive or processed in disagreement with the purposes for which he/she has given consent, observing, thereto, other rules of the legal system;
• Erasure Right; User may request the deletion of some data, except those in which the law authorizes its conservation;
• Information Right: User may request information from public and private entities with which Azevedo Prado carried out the shared use of their data, as well as the consequences if they choose not to consent to the collection and processing of their personal data;
• Refuse Marketing Right: User may, at any time, request the cancellation of receiving advertisements and other materials by means of the link provided in the marketing email sent.
• Portability Right: User may request their personal data to be transferred to themselves or to third parties, except for those that have already been anonymized and deleted by Azevedo Prado.
• Right to Withdraw Consent User may cancel any consent previously granted to Azevedo Prado to use their personal data. User is aware that the cancellation will not affect the use or sharing of data carried out prior to the consent revocation request.

The rights provided for in this chapter are not absolute, and the User must, whenever she/he wants to exercise them, contact Azevedo Prado on the channel: This email address is being protected from spambots. You need JavaScript enabled to view it.

Azevedo Prado undertakes to respond to such requests as soon as possible and at no cost to the User, limited to a maximum period of fifteen (15) days, counting from the receipt of the request, unless a longer period to respond due to complexity, reasons of fact or law, opportunity in which the User will be communicated.

Azevedo Prado will immediately inform the processing agents with which he has performed shared use of data on the correction, elimination, anonymization or blocking of the data, for them to repeat such procedure.

Confirmation of the existence or access to the User's personal data set forth in this chapter will be provided, electronically or expressly, in a simplified format or by means of a clear and complete statement, which indicates the origin of the data, the lack of registration, the criteria used and the purpose of the processing, always observing the trade and industrial secrets of Azevedo Prado.

Azevedo Prado and any partners may use cookies and other similar technologies to store and manage User preferences, offer targeted advertising, enable content and collect analytical and usage data, for example. The use of cookies and other tracking technologies is a standard on websites and platforms, through which information about User activities on the platform, websites or other services is collected.

A cookie is a small text file, placed on a computer or other device, used to identify the User, device used and to collect information, and can perform the following functions:

• Necessary Cookies: are essential to allow the User to navigate on a platform and use its resources.
• Performance Cookies: they collect information on how the User uses the Azevedo Prado platform and serve to improve his/her navigation and enhance the experience. The information collected includes, for example, internet browsers and operating systems used, the domain name of the previously visited website, the number of visits, the average duration of the visit and the pages viewed.
• Functional Cookies: they allow the platform to remember choices the User has made (such as their username or ID, language preference or the area or region where the User is located) and provide enhanced and more personal features.
• Advertising Cookies: they track the User's browsing habits and are used to deliver targeted advertising. These cookies also limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns. They also remember that the User has already visited a website and this information is shared with other organizations, such as advertisers.

Azevedo Prado uses necessary and performance cookies.

At any time, the User may disable Cookies by means of their browser settings, installing plug-ins available on the market, or even making use of other technologies that they deem necessary.

In addition to cookies, Azevedo Prado uses other tracking technologies, such as:

Web Server and Platform Records: Azevedo Prado servers automatically collect certain information to assist, manage and protect the services offered, as well as to analyze usage and improve the User experience. Information collected includes:

• IP address and browser type;
• Device information, including the Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA) and similar identifiers assigned by us or third parties;
• The device's operating system and other technical data;
• The city, state and country from which you are accessing the BRASIL RISK platform, including for fraud prevention;
• Typed information or texts;
• Links and buttons clicked;

Connections via Social Media: Some of Azevedo Prado services may include social media features, such as Facebook "Like" buttons and widgets; “Share” button and interactive mini-programs.

Azevedo Prado may allow the User to choose to use the logins of their own social medias to access some of the services offered, in which case Azevedo Prado may receive and store authentication information for these services.

Questions, comments, suggestions and/or complaints regarding this Privacy Policy, as well as any need for information, alteration or deletion of personal data, may be made by the User directly to Azevedo Prado, by email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Azevedo Prado seeks constant updates and improvements, so this Privacy Policy may be updated at any time, always aiming at better provision and protection for users.

In the event of changes that affect the purpose and duration of the processing of User's personal data, the User will be informed by the e-mail registered in our services or by the platform itself thirty (30) days in advance. If there is disagreement with the changes, the User may revoke the consent provided, being unable to use the services of Azevedo Prado Advocacia e Consultoria.

In case Azevedo Prado changes its policy in the future aiming sharing data with third parties, it will notice the user thirty (30) days in advance via the registered email, who may disagree with the sharing, at which time she/he will continue to use the services of Azevedo Prado.

User is advised to periodically read this policy to keep up to date with its content.

This Policy will be governed, interpreted and enforced in under the laws of the Federative Republic of Brazil, regardless the conflicts of these laws with the laws of other states or countries, the Forum of São Paulo being competent to resolve any doubt arising from this instrument, waiving any other, no matter how privileged it is.

All rights reserved.