Demonstrate Machado Meyer's commitment to the security and privacy of data/information collected from Users of the Machado Meyer's website and Third Parties.
2. DATE OF EFFECTIVENESS
This Policy is effective as of February 9, 2021, for an indefinite period of time, and may be revised and updated whenever necessary, according to the responsibility matrix provided in item 8 of this document.
3. TO WHOM IT APPLIES
The Policy applies to visitors and registrants on our Website, registered for Machado Meyer events, and to Third Parties visiting our Offices.
4. GENERAL GUIDELINES
4.1 The Policy will be published and disclosed internally on its intranet and externally on the website www.machadomeyer.com.br and will be available for reading, according to the following wording, directed to the specific public - "WEBSITE USERS AND THIRD PARTIES".
4.2 We explain in the Policy, in a clear and transparent manner, to the people who access and register on our Website and who register for events and who visit Machado Meyer's offices, what is done with the personal data we process.
4.3 The topics below clarify for what purposes personal Data of the persons indicated above is used, for how long, how you can access it, update it, and obtain additional information.
5. SPECIFIC GUIDELINES
5.1 We process data of the people who access the website www.machadomeyer.com.br who register to request information and/or receive communications that may be of interest to them, who register for events through our platform, and who visit our offices, in the following categories:
- Registration data (name, RG, CPF, nationality, position, e-mail, phone, mobile number, company, area of interest, date of birth, gender, contact person, CCTV image).
- Behavioral data (pages from the Website accessed, origin of access - e.g. google search).
5.2 Machado Meyer, as the controlling agent, will make decisions regarding the personal data processed within the scope of the relationship established with you.
5.3 We process personal Data for the following purposes:
- Prospect clients through research of contacts via internet and social networks;
- Maintain the Security and physical access control to the office premises;
- Promote brand value and engage with new contacts and potential clients through sponsored events;
- Establish a contact channel with the client through the Institutional Website;
- Enable online registration for events promoted by Machado Meyer;
- Offer legal services of interest to Users;
- Carry out relationship campaigns with potential clients.
5.4 We may share the Personal Data referred to in the Policy to render our services in the following instances:
Operating Agents who handle your personal Data in accordance with Machado Meyer's instructions:
- Technology service providers;
- Event organizing agencies to provide services requested by you or that may be of interest to you; and
- Providers related to physical security whenever you access our office premises.
5.5 Machado Meyer uses cloud systems, for this reason it is possible that Personal Data may be transferred outside Brazil (currently, to Chile and the USA), since they are the backup countries for the data storage of our service provider. To ensure that your Personal Data is processed solely for the stated purposes, we will adopt safeguards and guarantees such as specific clauses, standard clauses, and global corporate standards.
5.6 When you do not authorize registration in the mailing, Machado Meyer will not be able to send you additional information beyond that requested.
5.7 The Personal Data collected and processed shall be stored until the purpose of the Processing is exhausted or when there is no longer a legitimate purpose or a legal and regulatory reason that allows Machado Meyer to retain it.
5.8 We adopt security standards set forth in applicable laws and regulations, such as:
- Training, governance, internal security policies;
- Control of storage on internal or outside servers;
- Software to encrypt data collected;
- Protection against unauthorized access;
- Authorized access only to specific persons to the place where your personal information is stored, provided that such access is essential for the performance of the intended activity;
- Confidentiality of the professionals who access the information/data;
- Application of administrative, disciplinary, and legal sanctions against employees and persons who unduly use your information, in violation of this Privacy and Information Security Policy;
- Absolute commitment to the principles laid down by the applicable laws and regulations, as well as the storage and deletion of data, the latter when requested;
- Access by Data Subjects to all of their information stored.
5.9 While our best efforts are put into preserving your privacy and protecting your Personal Data, it is important for you to know that no transmission of information is ever completely secure.
For this reason, Machado Meyer cannot fully guarantee that all the information it receives and/or sends will not be subject to unauthorized access and performed through methods designed to obtain information improperly, such as viruses or database intrusions.
5.10 In the event of a breach of data in our custody, we guarantee we will make every effort to remedy the consequences of the event.
5.11 In order to ensure your privacy and the protection of your data, Machado Meyer will facilitate the exercise of the rights described in article 18 of Law 13,709/2018, General Personal Data Protection Law, as applicable, which are:
- confirmation of the existence of Processing;
- access to the data;
- correction of incomplete, inaccurate, or outdated data;
- anonymization, blocking, or elimination of unnecessary or excessive data or data processed in violation of the provisions of the General Personal Data Protection Law;
- portability of data to another provider of a service or product, upon express request, in accordance with the regulations of the national authority, subject to commercial and industrial secrets;
- erasure of personal data processed with the consent of the Data Subject, except in the cases provided for in article 16 of the General Personal Data Protection Law;
- information on public and private entities with which the Controller has shared the use of data;
- information about the possibility of not providing consent and the consequences of refusal; and
- revocation of consent, pursuant to paragraph 5 of article 8 of the General Data Protection Law.
5.12 To meet the above requests, we will undertake all reasonable efforts within the shortest time possible, but you should be aware that the following may occur:
- Possible delay in service due to justifiable factors, such as the complexity of the request;
- Rejection of your request for formal (e.g., if you are unable to prove your identity) or legal reasons (e.g., request for deletion of data that may be kept by force of law or regulation; request for copy of a document that will only be provided if there is explicit consent; request for portability due to lack of specific regulation for the activity performed by Machado Meyer).
5.13 For any case of impossibility of meeting your request, Machado Meyer will provide due reasons.
5.15 In the policy, all the relevant and necessary information regarding the Processing of your personal Data may be found and, therefore, we strongly recommend reading it in full.
5.17 When you visit our Website, cookies are exchanged with your browser when strictly necessary for the operation of the Website and for purposes of performance and targeting.
5.18 There are cookies that are responsible for tracking your personal preferences on our Website to provide greater functionality, such as language and text size, and to allow you to contact us via the "contact us" tab.
5.19 Strictly necessary and performance cookies are fundamental to our website and do not allow the identification of Users. Cookies for functionality and targeting purposes are optional you can manage and disable them according to your preference by clicking on here., refusing or deleting certain cookies and other technologies. However, this may prevent the functioning of certain features that integrate them. You can also see the list of cookies we use
6. TERMS AND DEFINITIONS
|Website user||Individual who accesses and registers on Machado Meyer's website.|
|Third Party||Individual who only visits the Website and the premises of Machado Meyer, or a person who signs up for events available on the Website.|
|Personal data||Any information relating to a directly or indirectly identified or identifiable individual.|
|Sensitive personal data||Special category of personal data concerning racial or ethnic origin, religious belief, political opinion, membership in a trade union or a religious, philosophical, or political organization, concerning health or sex life, genetic or biometric data concerning individuals.|
|Holder||Individual to whom the personal Data refers, such as, for example, the persons to whom this policy applies: persons who register on our Website (Users), visitors, and those enrolled in Machado Meyer events.|
|Data Protection Officer||Person appointed by the Controller and Operator to act as a communication channel between the Controller, the data Holders, and the National Data Protection Authority (ANPD).|
|Website||Designates the electronic address www.machadomeyer.com.br and its subdomains.|
|Processing||Any operation performed with personal Data, such as those relating to the: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, discarding, assessment, or control of the information, modification, dissemination, transfer, diffusion, or extraction.|
|Controller||An individual or legal entity, governed by public or private law, who is responsible for decisions concerning the processing of personal data.|
|Operator||Individual or legal entity, whether governed by public or private law, who carries out the Processing of personal Data on behalf of the Controller.|
- Code of Conduct
- Information Security Policy
- Physical Security Policy
- Document Management Policy
- Data Protection Standard
- Procedure for the enforcement of Data Holders' Rights
- ISO 27701
- Federal Law No. 13,709/2018 (General Personal Data Protection Law)
- Federal Law No. 12,965/2014 (Brazilian Civil Rights Framework for the Internet)
- Federal Law No. 8,078/1990 (Consumer Protection Code) and other applicable laws for the activity provided by Machado Meyer.
8. RESPONSIBILITY MATRIX
|Executive Board|| |
|Information Security and Privacy Committee (CSI&P)|| |
|Information Security|| |
|Responsible Person for personal data Processing (Data Protection Officer - DPO)|| |