Privacy Notice

Privacy Notice

Campos Thomaz (“Campos Thomaz“, “we” or “us”) is committed to making all clients and users that access its website (camposthomaz.com – “Website“) (jointly, “Data Subject” or “you“) aware of the information that is collected, stored or otherwise processed by Campos Thomaz. Our Privacy Notice aims to provide clear and precise information to the Data Subjects about the Processing of Personal Data by Campos Thomaz.

1. Definitions

The following terms may appear in this Privacy Notice:

• Controller: a natural person or legal entity in charge of making decisions concerning the Processing of Personal Data.
• Data Subject: natural person to whom the Personal Data processed refers.
• LGPD: Brazilian General Data Protection Law (Law No. 13,709/2018) and any further provisions to be specified, updated, amended, or replaced from time to time by the Brazilian Data Protection Authority or other applicable authority.
• Personal Data: any information related to an identified or identifiable natural person.
• Sensitive Personal Data: Personal Data involving racial or ethnic origin, religious belief, political opinion, affiliation to a union or religious, philosophical or political organization, data relating to health or sex life, genetic or biometric data, whenever related to a natural person.
• Processing: any operation carried out with Personal Data, such as collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, information evaluation, or control.
• Data Protection Officer (DPO): an individual or legal entity appointed by the controller and processor to act as a communication channel between the controller, data subjects, and the National Data Protection Authority (ANPD).

2. Who is the controller of your personal data?

Campos Thomaz Advogados, enrolled with the CNPJ under No. 38.198.432/0001-21, headquartered at Rua Funchal, 551, Conj. 51, Vila Olímpia, São Paulo/SP, CEP 04.551-060, is the controller of your personal data. Under the applicable law, the controller is the party responsible for making decisions regarding data Processing.

3. Contact Information of the Data Protection Officer (DPO)

In compliance with the provisions of Article 41, § 1 of the LGPD and Article 9 of Resolution CD/ANPD No. 18, we hereby clearly and objectively inform you that the DPO of Campos Thomaz is Mr. Alan Campos Elias Thomaz, with the members of the Executive Committee designated as substitute DPOs, if necessary.

If you have any questions regarding this Privacy Notice, including any requests to exercise your rights, please email the data protection department at privacidade@camposthomaz.com.

Our DPO is available to assist you in the best possible way.

4. Which Personal Data is processed by Campos Thomaz?

Campos Thomaz needs to process Personal Data to comply with legal or regulatory obligations and contract execution, especially for the provision of legal services. Campos Thomaz may also process your Personal Data under its legitimate interests in the administration and management of its services or with your consent.

Within limits permitted by applicable law, Campos Thomaz may process the following types of Personal Data:

(i) Client’s Personal Data:

– Registration data: first and last name, nationality, birth date, gender, address, email address, telephone number; identification documents (such as ID number, taxpayer registration card (CPF), driver’s license, professional card, as applicable)

– Professional data: profession, position, company where you work; telephone and business address

– Financial data: banking details and remuneration, as applicable

– Data related to the provision of legal services: for the provision of legal services, Campos Thomaz may access and process a large volume of your data or even Personal Data  of others involved in a certain case (for example, your employees, third parties, the other party in a lawsuit, among others), depending on the object or reason of the consultation or claim. Some examples of Personal Data that Campos Thomaz may process in the provision of its services are (i) communications with representatives of our clients and identification of persons involved in specific jobs and (ii) financial information (remuneration and payments, transaction history, and credits)

– Navigation data: IP address, traffic data

(ii) Website Users’ Personal Data:

– Navigation information: We collect information about your visit to the website, such as the browser you are using, the domain name of your Internet service provider, and the sort of operating system used by you

– Contact Information: When you email us or fill out our online newsletter forms, we ask for Personal Data (such as your name, phone number, and email address) so that we can respond to your inquiry and/or register you on our systems to send you newsletters

– User communications: When you contact Campos Thomaz, send us an email address or messages through our communication channels, we may retain your information to process your questions, respond to your requests, and/or improve our services

(iii) Personal Data Related to Partners, Service Providers, Suppliers, and Casual Workers:

– Identification, qualification, and contact information: full name, email address, telephone number, address, nationality, marital status, profession, identification document (such as identity card, taxpayer registration card, driver’s license, or similar document), gender, signature, photo, security camera images, among other information, as applicable

– Professional information: company’s name, workplace, position, address, and business telephone number

– Remuneration and related data: bank account data, invoice, tax information, and third-party information as required for payment and banking transactions

(iv) Personal Data Relating to Guests and Participants of Events:

– Identification, contact, and registration data: full name, email address, telephone number, address, nationality, country, city, profession, identification document (identity card, taxpayer registration card, professional card, driver’s license, or similar document), areas of interest, language, among other information, as applicable.

– Professional data: company’s name, where you work, position, address, and telephone number.

Campos Thomaz may collect the information listed above (i) directly from the Data Subjects, (ii) from someone related to the Data Subject (for example, the company you work for), (iii) from publicly accessible sources, or (iv) from site traffic. Regardless of the data origin, the Processing will be governed by this Privacy Notice. You may contact us at privacidade@camposthomaz.com in case of any doubts.

For Personal Data relating to candidates for vacancies at Campos Thomaz, please see our Privacy Policy for Candidates.

5. For what purposes do we collect and process your Personal Data?

In general, we process your Personal Data for providing legal services, such as advisory or litigation services, including, but not limited to:

• Providing legal services and managing relationships with our clients
• Drafting, reviewing, or negotiating agreements
• Developing or participating in audits to verify a company’s compliance with Brazilian law and risk analysis
• Managing investigations, inquiries, legal, administrative or arbitration proceedings, which includes the analysis and drafting of documents, and follow-up on progress, among other actions
• Analyze new products, structures, cases, or situations clients present to prepare answers to inquiries, memos, legal opinions, or opinions.
• Drafting of mandatory documents under Brazilian law
• Compliance with legal or regulatory obligations
• Defense in judicial, administrative, or arbitral proceedings
• Intermediation of the client’s relationship with authorities and governmental entities
• Pro bono work
• Conducting training sessions
• Registration and participation of Data Subjects in our events
• Holding meetings, videoconferences, or conference calls to discuss general issues
• Obtaining necessary licenses, authorizations, and permits
• Assistance in participating in tenders
• Coordination of merger, acquisition, or capital market operations
• Legitimate interest of Campos Thomaz
• Legitimate interest of the Data Subjects
• Maintaining our relationship with you by sending communications (i) administrative and institutional communications, (ii) on privacy issues, and (iii) invitations to events and other promotional content
• Organizing events, including managing registrants, sending save the date, reminders, and thank you notes. In this case, we may collect Personal Data on whether you have a disability or mobility restriction
• Conducting satisfaction surveys and feedback on our services and initiatives

To opt out of receiving further newsletters or promotional email addresses, click on the link found at the bottom of our email address.

Occasionally, Campos Thomaz may indicate your Personal Data so that national or international legal publications may contact you to evaluate and refer our services to such publications.

6. With whom do we share your Personal Data?

Campos Thomaz may share your Personal Data with third parties or business partners that provide services to us, such as financial and statistical services, information technology, marketing, and social network management, including the following categories of third parties:

• Providers of software and other information technology to manage electronic forms, file storage, and other administrative functionality necessary for the operation of Campos Thomaz
• Providers of email address services to enable us to communicate with you
• Web analytics servers so that we can identify your browsing patterns on our site and provide a better experience for you
• Accountants to assist us in recording payments and reporting to the applicable authorities
• Correspondents, experts, consultants, partner firms (national and international), auditors, accountants, translators, and financial institutions assist in providing legal services, depending on the demand
• NGOs in case of pro bono work
• National or international legal publications
• Regulatory bodies and other authorities, such as the Brazilian National Data Protection Authority (ANPD)

Campos Thomaz may also share your Personal Data with third parties (including governmental entities) to respond to investigations, judicial measures, and legal proceedings or to investigate, prevent or adopt measures about illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, or if otherwise required by law.

7. International Transfers

Campos Thomaz may transfer some of your Personal Data to service providers located abroad, including cloud service providers. In addition, Campos Thomaz may share your Personal Data with other Campos Thomaz offices located abroad or with partner offices located outside Brazil.

When your Personal Data  is transferred outside Brazil by Campos Thomaz, we will adopt appropriate measures to ensure adequate protection of your Personal Data  in compliance with the requirements of the applicable data protection legislation, including by entering into appropriate data transfer agreements with third parties of your Personal Data , when necessary.

8. For how long do we retain your Personal Data?

We store and maintain your information: (i) for as long as required by law – during the applicable statute of limitations or for as long as necessary to comply with a legal or regulatory obligation; (ii) until the termination of the Processing of Personal Data, as mentioned below; or (iii) for as long as necessary to preserve the legitimate interest of Campos Thomaz.

We will refrain from Processing your Personal Data in the following cases:

– When the purpose for which the Personal Data was collected is reached and/or the Personal Data collected is no longer necessary to reach such purpose;

– When you have the right to request the termination of the Processing and the deletion of their Personal Data and do so; and

– When there is a legal determination to do so.

In these cases of termination of Personal Data  Processing, except in the cases established by the applicable legislation or by this Privacy Notice, the Personal Data will be deleted.

You may request the deletion of your data at any time by sending an email address to privacidade@camposthomaz.com.br.

9. Your rights as a Data Subject

You will have certain rights in relation to your Personal Data, as provided by law. Such rights include, but are not limited to:

• Receive clear and complete information about how we process your Personal Data, including if we share your Personal Data
• To access your Personal Data and/or confirm the existence of data Processing
• Request that we rectify any inaccurate, incomplete, and outdated Personal Data
• Oppose the Processing activities, request the anonymization and deletion of Personal Data that are unnecessary, excessive, or processed in violation of the provisions set forth in the LGPD
• Request the portability of your Personal Data
• Revoke your consent at any time, if when Campos Thomaz processes your Personal Data based on consent, except in the cases set forth in the LGPD
• Request that automated decisions that may affect your interests are reviewed

You may exercise such rights by contacting our Data Protection Officer (DPO) at privacidade@camposthomaz.com.

Please contact our DPO to update or review the Personal Data that Campos Thomaz processes about you.

10. Cookies and Similar Devices

A cookie is a small amount of data that may be sent and stored in your browser from a website for record-keeping purposes. Campos Thomaz may use cookies for specific purposes, including, but not limited to:

• Identifying the pages and content that you most access when navigating our website, for statistical purposes only. It helps us improve our services, offering a better experience for you.
• Facilitating you to fill out forms to access certain content provided by Campos Thomaz

11. Security Measures

Campos Thomaz employs security measures to protect your Personal Data and prevent unauthorized access, accidental loss, destruction, or damage to information that we collect. Your Personal Data is securely stored on protected equipment. Only a limited number of people will have access to such equipment, and only individuals with legitimate reasons to do so will have access to your Personal Data.

12. Third-party websites and links

Our website may contain links to other sites over the internet. Campos Thomaz is not responsible for those websites and the content shared therein and does not endorse, monitor, validate or accept how those websites process your Personal Data. We recommend that you consult the privacy policies of such websites to be adequately informed about Processing your Personal Data, as we have no control over information that is submitted to, or collected by, these third parties.

13. Revisions to this Privacy Notice

We reserve the right to revise this Privacy Notice or any part of it from time to time by publishing the updated version at www.camposthomaz.com.

14. How to contact us

If you have any questions about this Privacy Notice or want to contact us about your privacy and how we process your Personal Data , you may contact us or our DPO at privacidade@camposthomaz.com.

Last updated: December 2024.