Privacy Policy

Last update: September, 2020.

TozziniFreire values the privacy of those who provide personal data to us. This Privacy Policy (the “Policy”) describes how and why we collect, store and use personal data, and provides information about individuals’ rights.

This Policy applies to personal data supplied to us either by an individual or by others.  We may use personal data supplied to us for any of the purposes as set out in this Policy, or as otherwise disclosed at the point of collection.

In this Policy, we use the terms:

“We”, “us”, and “our” (and other similar terms) to refer to  any entity which is a member of the Brazilian TozziniFreire network, which includes its partners, associates, interns, administrative employees and other members directly related to TozziniFreire. In this case, TozziniFreire acts as Personal Data controller and is responsible for making decisions related to the processing of Personal Data of the data subjects. For this reason, we have a legal obligation to keep a record of the processing operations we carry out, indicating the purpose, processing term, security, privacy, and consent records (as applicable).

“Personal Data” to refer to any information relating to an identified or identifiable natural person, who can be identified, directly or indirectly; and,

“You” and “your” (and other similar terms) to refer to our clients, individuals associated with our clients, contacts, suppliers, job applicants, staff and visitors to the TozziniFreire website, www.tozzinifreire.com.br. In this case, you are the data subject and, for this reason, you have certain rights that we describe below.

Legal basis for processing

We from TozziniFreire, as controller, will only process Personal Data where we have a lawful reason for doing so. The lawful basis for processing Personal Data by us will be one of the following:

  • the data subject has given consent to the processing of their personal data for one or more specific purposes;
  • the processing is necessary for the execution of an agreement we entered into, or are going to enter into with you;
  • the processing is necessary to achieve our legitimate interests;
  • the processing is necessary to comply with a legal obligation.

Your rights in relation to Personal Data

 Under certain circumstances, you, as data subject, have the following rights:

  • the right to confirm whether we are processing any Personal Data related to you;
  • the right to request that we disclose or provide you with access, in a clear, adequate, and ostensible way, to the information regarding the processing of your Personal Data, such as specific pieces of Personal Data we have collected about you;
  • the right to know the categories of sources from which we collected your Personal Data, the purpose of its processing, the period for which it will be stored, and the categories of third parties with whom we shared your Personal Data;
  • the right to have corrected any incorrect, incomplete or out-of-date information that we have relating to your Personal Data;
  • the right to request, at any time, the erasure of your Personal Data, except if the deletion request is against the retention obligations detailed below;
  • the right to request, at any time, the anonymization or block of your Personal Data that are not necessary or processed in compliance with the law;
  • the right to be informed about which, if any, public and private entities have we shared your Personal Data; and,
  • withdrawal of consent – when Personal Data is processed on the basis of consent; you may withdraw your consent at any time.

Additionally, in the event you no longer want to receive any marketing material from us, please use the unsubscribe option (which is available in all of our marketing emails to you), or contact us by email at dpo@tozzinifreire.com.br.

To exercise such rights that Brazilian General Data Protection Law provides for you and solve any questions you may have about how we collect, store and use Personal Data, please contact us at dpo@tozzinifreire.com.br. We will be pleased to clarify any questions.

Personal Data collected

We aim to be transparent about why and how we process Personal Data.  If we ever intend to use your Personal Data for any other purpose that is not described here, we will ask for your consent before proceeding, unless it is to fulfill a legal obligation or to serve our legitimate interests. Anyway, please find below further information on our processing activities:

Data Collected

Purpose

Clients

Name, email address, function, telephone number, area of business and any information you may provide us related to the project that we may jointly develop.

Grant access to our services based on the information you provided.

Providing legal services: we will use and disclose Personal Data in such a manner as we believe is reasonably necessary to provide our services. For example, we may need to instruct overseas counsel on your behalf (including correspondence with you), to liaise with other professional service providers in relation to matters that we are handling, or because we need to liaise with the opposing party on a matter you have instructed us on.

Administration: to collect our fees or costs in connection with our services.

Managing client relationships: providing clients with information on our services and legal updates that we consider may be relevant to them; arranging and hosting events; and identifying where we may make improvements in service delivery.

Client engagement: as part of our client onboarding process we carry out certain background searches to verify whether or not there are any potential issues that may mean we cannot work with a particular person (to identify criminal convictions, politically exposed persons, sanctions or other potential reputation issues).

Website Guests

Browsing history (accessed pages, date, time, location of access and IP address), whenever you access the website.

Grant access to our services based on the information you provided.

Enable us to contact you in case you need any assistance while navigating through our website or using our services.

Assure the safety of your information; avoid fraud; unauthorized access; and other inappropriate or illicit uses of your information.

Develop and improve our communication methods, services and other functionalities of the website.

Provide you information related to the website and keep you informed about our services, changes in this Policy or in your account.

We also use cookies in our website to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. This information will not be shared with third parties without your consent and will be eliminated or anonymized, in the case of non-use, to comply with legal obligations.

Name, email address, job title, telephone number, area of business, job role, jurisdiction, language, seniority and other business contact information.

 

Grant access to our services based on the information you provided.

Enable us to contact you in case you need any assistance while navigating through our website or using our services.

Assure the safety of your information; avoid fraud; unauthorized access; and other inappropriate or illicit uses of your information.

Develop and improve our communication methods, services and other functionalities of the website.

Provide you information related to the website and keep you informed about our services, changes in this Policy or in your account.
 

Contact and communication purposes: send you legal updates from time to time, news about any events we are organizing or participating in, and/or other information about us and the services that we believe may be of interest to you. 

We may also use your Personal Data for performing analytics, such as trends, sales intelligence, marketing effectiveness (such as click and open rates) uptake and progress. This information will not be shared with third parties without your consent and will be eliminated or anonymized, in the case of non-use, to comply with legal obligations.

 

Job Applicants

Name, email address, telephone number and other business contact information, as well as your curriculum vitae may be collected when applying online.

Grant access to our services based on the information you provided.

Enable us to contact you in case you need any assistance while navigating through our website or using our services.

Contact you to about job opportunities that may be of your concern and send you job proposals.

Invite you to participate in interviews.

Store your curriculum vitae in our for future opportunities database, in case it is of interest to you to receive future alerts.

Students

Name, email address, educational institution, telephone number, area of study and any information you may provide in a student’s fair event.

Contact you about job opportunities that may be of your concern and send you internship proposals.

Invite you to participate in internal interviews.

Former Employees

Name, email address, telephone number, area of business and any information you may provide in the moment of the shutdown.

Contact you to participate of Alumni Program, send you communications about events and newsletters that may interest you.

 

For how long may we keep your Personal Data?

Personal Data is retained for as long as it is necessary for the purposes set out above (being the length of our relationship). 

We may delete your contact information from our database, as well as your personal data, subject to your request. However, if you opt out of receiving marketing materials, your personal data will still be retained (as our lawyers may still be in contact) but marketing materials will no longer be sent.

We have the legal obligation to retain the access registrations (meaning the dates and times an application was used from a given IP address) of our website for a 6-month term, subject to extension upon request from the Police Authorities, administrative authorities.

 

Additionally, we are also obliged to store evidence of your consent to our data processing during the term of our business relationship.

Who else may have access to your Personal Data?

You acknowledge and consent that we may need to share your Personal Data with third parties.  We will only share Personal Data where we are legally permitted to do so.

By providing us with Personal Data as a client you acknowledge and consent that we can disclose your Personal Data in such manner as we believe is reasonably necessary to provide our services (including as described in this Policy), or as is required under applicable law. This might be because, for example, we may pass your Personal Data to third parties such as:

  • business partners, service providers and other affiliated third parties: to enable us to provide our services to you, we may need to share your Personal Data with our business partners (including other professional advisers such as accountants or auditors), external service providers and/or overseas counsel. Our arrangements with external service providers currently cover the provision of support services including IT, events management, document production, business and legal research, secretarial services, marketing and business development and facilities management;
  • disclosures required by law or regulation: in certain circumstances, please note that we may be required to disclose Personal Data under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings.

International transfers of Personal Data (including to outsourced service providers)

From time to time, we may need to transfer your Personal Data to affiliated law firms located abroad in order to provide you with the services required. We shall not transfer your Personal Information to third parties located abroad without your previous and express consent.

Cookies

A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the website you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content; and (v) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files. By consenting to this Policy, you agree that we may use cookies to improve your browsing experience through our website.

Links to other websites

The TozziniFreire website, www.tozzinifreire.com.br, may link to other, unaffiliated third party websites. Please note that TozziniFreire is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third party websites.  You must always carefully review the privacy policy of any third party website that you may visit in order to understand how the operators of that website may collect, store and use your Personal Data.

Updates to this Policy

This Policy was last updated on the date indicated above. We will inform you every time there is a material change in this Privacy Policy.

Complaints

While we hope that you will not need to, if you want to complain about our use of Personal Data please send an email message at dpo@tozzinifreire.com.br, detailing your complaint.

Communication

If you still have any query regarding the purpose to which we use your Personal Data, or if you have some criticisms and/or suggestions please do not hesitate to contact us through the e-mail dpo@tozzinifreire.com.br.