Privacy Policy

1. Purpose of this Policy

FFSA – Filgueiras e Fleury Sociedade de Advogados, SP, RL (“FFSA” or “we”) is committed to raising awareness among our clients, individuals and representatives, business partners, associates or any other individuals related to FFSA’s corporate clients (“Data Holder”, “Holder” or “you”) regarding the personal data processed by FFSA.

With a commitment to respecting your privacy and transparency, FFSA has created this privacy policy (“Privacy Policy”) to provide you with a clear understanding of how FFSA handles your personal data.

2. Who is the personal data controller?

FFSA will be the controller of your personal data within the scope of the relationship established with you. For the purposes of the applicable legislation, the controller is the person responsible for decisions regarding the processing of personal data.

3. What personal data is processed?

To the extent permitted by applicable law and depending on your relationship with the firm, FFSA may process the personal data described below.

• Identification, qualification and contact details: full name; address; date of birth; nationality; details of identification document(s), email address; telephone number;
• Academic and professional data: company you work for; occupation; position; education.

In the provision of legal services, considering the support provided to clients in the most diverse areas and specialties of Law, FFSA may have access to and process a certain list of your personal data or even the personal data of others involved in a given case (for example, the other party in a lawsuit), depending on the purpose or cause of the claim. Some examples of personal data that FFSA may process in the provision of its services are:

• Registration information: Name, NIF, Citizen Card, Residence Permit, Passport, address and telephone number;
• Financial information: remuneration; transaction history; credits; sales; possessions; debt certificate; loans;
• Family information: family structure; relationships;
• Information in files: date of birth, nationality, place of birth, age, marital status, country, address, occupation, education, languages, professional registration.

The above personal data is processed only in certain cases and when necessary to achieve the purposes mentioned in this Privacy Policy, in particular for the provision of legal services.

FFSA may collect this information in various ways. This personal data may be collected directly from the Data Holder, it may be obtained from someone related to the Data Holder (e.g. the company you belong to) or it may be accessed from publicly accessible sources.

4. For what purposes do we process your personal data?

In general, we process your personal data for client service and the provision of legal services within the advisory or litigation scope.

We may also process your personal data for the purposes of formalizing the contract with FFSA, billing and collection if you are the individual client or the representative of a legal entity client.

In addition, we may process your personal data to maintain our relationship with you through:

• Sending institutional communications, memos or newsletters on topics of interest to you and inviting you to events;
• Organizing events, including managing registrations, reminders and acknowledgements;
• Carrying out satisfaction and feedback surveys on our services and initiatives.

FFSA may provide your personal data to domestic or international legal publications from time to time to contact you so that you can evaluate and refer our services to such publications.

If you are a partner of FFSA (i.e. a natural person partner or representative of a legal entity partner), we will process your personal data for the purposes of establishing and managing such a partnership. In this sense, we may process your personal data to formalize the contract with FFSA, to send you communications related to the partnership, to comply with our obligations in the context thereof. We may share some of your personal data with FFSA clients or third parties, always to the extent necessary and with the aim of ensuring that the partnership develops satisfactorily.

5. With whom do we share your personal data?

FFSA may share your personal data with:

• Providers of software, cloud hosting services and other information technologies for the purposes of managing your relationship with our firm, registration, documentation and other arrangements;
• Agents, experts, consultants, partner firms (domestic and international), auditors, accountants, translators and financial institutions to assist in the provision of legal services, depending on demand;
• Non-governmental organizations in the case of pro bono work;
• Domestic or international legal publications;
• Regulatory bodies and other state or non-state authorities.

6. Transfers of your personal data outside Brazil

FFSA may transfer your personal data to service providers located abroad, including cloud service providers. In addition, FFSA may share your personal data with other FFSA offices located abroad or with partner offices, provided that is authorized by the Data Holder.

When your personal data is transferred outside of Portugal by us, FFSA will take appropriate measures to ensure adequate protection of your personal data in accordance with the requirements of applicable data protection legislation, including by entering into appropriate data transfer agreements with third parties of your personal data, where necessary.

7. How long will we keep your personal data?

We store and keep your information: (i) for as long as required by law; (ii) until the end of the processing of personal data, as mentioned below; (iii) for as long as necessary to preserve FFSA’s legitimate interest, as the case may be; (iv)for as long as necessary to safeguard the regular exercise of FFSA’s rights in judicial, administrative or arbitration proceedings. Thus, we will process your data, for example, during the applicable limitation periods or for as long as necessary to comply with a legal or regulatory obligation.

The processing of personal data will cease in the following events:

• When the purpose for which the Data Holder’s personal data was collected has been achieved and/or the personal data collected is no longer necessary or relevant to the achievement of that purpose;
• When the Data Holder is entitled to request the termination of the processing and the deletion of his/her personal data and does so; and
• When there is a legal determination

8. What are your rights in relation to your personal data?

You have the following rights with regard to your data: (i) confirmation of processing; (ii) access; (iii) correction of incomplete, inaccurate or outdated data; (iv) anonymization, blocking or deletion; (v) portability; (vi) deletion; (vii)information on sharing; (viii) information on the possibility of not providing consent and the consequences of refusing; (ix) revocation of your consent, if we have requested it from you; and (x) right to petition the public body responsible for regulating data protection.

There are circumstances that may restrict the exercise of some rights reviewed by law, such as, for example, when the provision of information may reveal a FFSA business secret or due to compliance with any legal/regulatory obligation or to allow the FFSA defense in any judicial or administrative proceeding.

You may exercise these rights by contacting FFSA at the following email address: contato@ffsa.pt.

9. Data protection and security

We are committed to the security of your personal data and take reasonable precautions to maintain this protection. FFSA employs industry-standard security systems and technical, physical and managerial procedures to protect your data.

We remind all clients that we will never send electronic messages requesting confirmation of personal information by email. For this reason, we are not responsible for any fraudulent electronic communications that collect your personal data (phishing). With regard to emails received, we recommend checking the content of the entire email before clicking on any web address or link. Make sure that emails containing a suspicious header and sender field or strange content, messages that contain errors in Portuguese or even faulty photographs and logos.

10. Cookies

By accepting this Privacy Policy, you agree to the processing of cookies, in accordance with the definitions and terms set out below.

Definition: These are data files recorded on the device of a visitor to a website or portal (via smartphone, tablet or computer) which record information on user preferences, location, pages visited, among others, and which offer greater convenience in browsing.

Classification:

 In terms of validity:

Session cookie: these are temporary and remain until the web page or browser is closed. They may be used in e-commerce to analyze internet traffic patterns and to provide users with a better experience and contextualized content.

Permanent cookie: persist even if the browser is closed. They may be used to remember users’ login and password, for example, or to ensure a better user experience between different sessions.

 Purpose

Strictly necessary: essential to allow the user to use the websites, applications and services offered, which could not be properly offered without these Cookies. They are generally session cookies.

Performance: they collect anonymous information on how users use and interact with the websites, applications and services offered, making it possible to recognize their profiles and account for visits and interactions.

Functionality: they allow you to remember choices made by users (such as login and location) and provide more personal experiences, as well as allowing for possible customizations (when they are available). This information can be anonymized (becoming Anonymized Data) and does not track activities outside the websites, applications and services offered. It is generally permanent.

Analytics and advertising: allow advertisers and partners to deliver more relevant ads and information to users. They are also used to limit the number of times a user sees certain ads and to measure the effectiveness of advertising campaigns. They remember certain user preferences and are used to help profile users in order to improve the user experience. They are generally permanent.

How cookies may be used by FFSA:

The FFSA may or may not use cookies when a user accesses the internet portals it owns.

Cookies are only associated with the browser of a particular computer and do not provide references that allow the user’s first and last name to be deduced.

Because of cookies, FFSA can recognize users who have registered on a previous use of the pages, so that they do not have to register on each new visit.

The cookies that may be used on the sites and web pages of FFSA’s Internet portals may be installed by FFSA, which originate from the different servers operated by FFSA, or from the servers of third parties that provide services and install cookies for FFSA.

In order to use FFSA’s web portals it is not necessary for the user to allow the reception of cookies sent by FFSA, although in this case it will be necessary for the user to register each time they access a service that requires prior registration.

Whenever the option to prevent the installation of cookies has not been activated, the user may search their computer’s hard disk in accordance with the browser’s own instructions. Information on this configuration is available in the browser’s instructions and manuals, as shown below.

Internet Explorer: https://support.microsoft.com/pt-br/help/17442/windows-internet-explorer-delete-manage-cookies

Mozilla Firefox: https://support.mozilla.org/pt-BR/kb/ative-e-desative-os-cookies-que-os-sites-usam

Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=pt-BR

Safari: https://support.apple.com/pt-br/guide/safari/sfri11471/mac

It is important to note that the correct functioning of FFSA-owned internet portals cannot be guaranteed if strictly necessary cookies are denied.

11. Changes to this Privacy Policy

FFSA reserves the right to amend this Privacy Policy at any time, by publishing an updated version to be notified to our clients.