Privacy Policy

GALEAZZI & ASSOCIADOS CONSULTORIA E SERVIÇOS DE GESTÃO EMPRESARIAL LTDA (“Galeazzi”) is committed to complying with laws that protect the privacy of customer data and the general public. This Privacy Policy (“Policy”) provides information about what information we collect from you, how that information is used, how we protect it, and how we act to ensure that your Personal Data is processed in accordance with required legal standards, 13.709/2018 (General Personal Data Protection Law or “LGPD”). Please read the information below carefully. The use of our products and services, as well as our platforms, and other available means of interaction, is conditioned to the acceptance of this Privacy Policy.

1. How we collect your Personal Data

When you use our services and products, we may collect and store your information directly as described below:

• Registration Data. Names and contact details such as first and last name, email address, postal address, telephone number and other similar types of contact details such as bank details;

• Support Information. When you ask our Support team for help, we will collect and store the contact information you provide (usually your name and email address). We will also store correspondence and all information contained therein.

• Device Information. Information about your device, such as your IP address, location or provider, information about your location, and your operating system version;

• Usage Information and Browsing History. Information and statistics about your use of our platform/site or our services, and your browsing history; and

• Cookies, as detailed in section 8.

From time to time, Galeazzi may collect and process Sensitive Personal Data. Galeazzi will only process such data if it has a legal chance of processing to do so, for example, if it is necessary for our compliance with a legal or regulatory obligation, or if you have given us your explicit consent. In this case, you will be informed of its specific purpose at the time of collection.

The information available on Galeazzi's channels is not intended for children and youth. Our website may only be accessed by persons over the age of eighteen. Galeazzi does not collect data from minors, except with the permission of their parents or guardians.

2. How we use your Personal Data

In general, we will only use your personal data for the purposes described in this Policy or for the purposes that we explain to you at the time of collection of your Personal Data. These purposes include:

• Provide and improve the contracted services;

• Comply with our legal or regulatory obligations;

• Manage our relationship with you and provide you with a personalized experience;

• Set up and administer your account, including to confirm your identity and ensure its security;

• Provide you with technical assistance, support and training, as well as answer your questions;

• Contact you when necessary to, for example, confirm or cancel requests through the use of the platform; communicate future changes that this policy may undergo; and disclose updates, changes, additions of new data sources and improvements to the platform;

• Development, improvement, testing and implementation of new features and functions of Galeazzi's services;

• Personalize and make available marketing, advertising and advertising content, including from Galeazzi Partner companies, as permitted by law;

• To prevent, detect, mitigate and investigate fraud or potentially illegal activities, and to meet internal and external audit requirements, including Galeazzi's information security obligations;

• To serve Galeazzi's legitimate interests, including, but not limited to, maintaining and guaranteeing your privacy, the security of our networks, systems and Galeazzi and/or third parties' properties;

• Comply with requests from courts, law enforcement, regulatory bodies and other public institutions and government authorities, including, but not limited to, any rules in force outside your country of residence; and

• The regular exercise of Galeazzi's rights, including in judicial and extrajudicial actions, as well as for the good performance of our contracts.

3. Sharing of Personal Data

We may share some of your Personal Data with third parties, including, but not limited to:

• Companies that provide your access or are responsible for your registration;

• Companies that help us offer our services or that can take action on our behalf, protecting our rights, users, systems and services;

• Public bodies and authorities to which Galeazzi has a legal or regulatory obligation to disclose information, such as regulatory agencies, police authorities and the Judiciary;

• Situations of sale, merger, acquisition, restructuring, joint venture, assignment, or transfer of part or all of Galeazzi's business, in which case the User's data will be considered an asset and transferred in an eventual negotiation;

• Maintenance and guarantee of security, fraud prevention, payment processing, hosting services, customer service and other sharing situations to protect Galeazzi's rights and legitimate interests; and

• With any natural or legal person to whom you request the portability of your data, within the limits of legal regulations. We instruct all third party service providers to maintain the confidentiality of information disclosed to them and not to use your information for any purpose other than fulfilling the aforementioned processing purposes.

4. International Transfer of Personal Data

Galeazzi does not intend to transfer your Personal Data outside Brazil, given that, in the event of a transfer, you will be informed in advance by email, at which time you may or may not accept it; however, in case of disagreement, access to Galeazzi services may be restricted or prevented.

5. Security

Galeazzi uses appropriate technologies and procedures to protect your Personal Data (including administrative, technical and physical protections) against Security Incidents, according to the level of risk and the service provided, having a legally responsible team to deal with the secure 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.

Galeazzi uses 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 protection software. against unauthorized access to systems, as well as standard methods for encrypting and anonymizing collected data. This Policy represents Galeazzi's effort to protect your information.

However, please note that you are solely responsible for your login and password to access the platform and, consequently, undertake not to inform and/or disclose, whether intentionally or not, such information to third parties. Likewise, you are solely responsible for the activities carried out on the platform through your login and password.

You are also required to promptly notify Galeazzi of any: (i) unauthorized use of your account by any third party; (ii) request of your data by third parties that make unauthorized use of brands, domains or denominations linked to Galeazzi; and (iii) unauthorized access to your personal or registration data by any third parties.

Galeazzi is not liable for any damages arising solely from the fault of third parties, such as in the case of a hacking or cracking attack, or when you are solely responsible, as in the case where you transfer or disclose your Personal Data to a third party.

6. Period for processing Personal Data

Your Personal Data will, as a rule, be deleted after the end of its treatment, within the scope and technical limits of the activities. Galeazzi calculates the retention period of personal data according to the following criteria:

• Period necessary to achieve the purpose of collection (for example, when you stop using Galeazzi's services or, if applicable, when your consent is revoked and your Personal Data is requested to be erased);

• The time required to demonstrate compliance with Galeazzi's duties and obligations, including the necessary storage period provided for by law, regulations, court decisions and the like;

• Determinations, guidelines and regulations of the National Data Protection Authority;

• The faithful fulfillment of our legal or regulatory obligations;

• The perfect execution of the contract; and

• The necessary maintenance of our legitimate interests and the defense of our rights. Note that your Personal Data may be kept after the end of its treatment for the fulfillment of legal or regulatory obligations or our exclusive use, in this case, however, with the anonymization of such data.

7. User Rights

According to the LGPD, you have the following rights regarding the processing of your personal data:

• Confirmation and Access: right to obtain information about the Processing of your Personal Data by Galeazzi and to verify that this Processing is legal, as well as the right to access your Personal Data;

• Correction: the right to obtain from Galeazzi the rectification of any incomplete, inaccurate or outdated Personal Data concerning you;

• Revocation of Consent: you may revoke the Consent given at any time, upon express expression. All Treatment carried out during the term of the Consent given will remain valid;

• Deletion of data: you have the right to have your data processed with your consent deleted, within the scope and technical limits of our activities, except when authorized or mandatory for its conservation;

• Anonymization: the right to anonymization, blocking or deletion of unnecessary, excessive or processed data in violation of the provisions of the LGPD;

• Information: right to information of public and private entities with which Galeazzi shared data use;

• Portability: right to transfer your Personal Data to another service or product provider, upon express request, in accordance with ANPD regulations, except for those that have already been anonymized and excluded by Galeazzi. To exercise any of the above rights, simply send an express request – in person or through a legally constituted representative – to This email address is being protected from spambots. You need JavaScript enabled to view it.[, or by correspondence to Rua Brigadeiro Faria Lima, 10º andar, São Paulo – SP – 01452-001, specifying:

• Full name, CPF number, email address of the Holder and, if applicable, of its representative;

• Right you wish to exercise with Galeazzi;

• Order date and signature;

• Any document that can demonstrate or justify the exercise of your right.

Galeazzi undertakes to respond to such requests within the legal deadlines and without cost, unless a longer period is necessary to respond due to complexity, reasons of fact or of law, in which case you will be duly communicated.

Galeazzi will immediately inform the processing agents with whom it has shared your data about the correction, elimination, anonymization or blocking of data, so that they can repeat the same procedure.

8. Cookies

Galeazzi and any partners may use cookies and other similar technologies to store and manage your preferences, offer you targeted advertising, enable content and collect analytical and usage data, for example. A cookie is a small text file saved on your device when you access the platform, and is used to identify you and to collect information, and can perform the following functions:

• Necessary Cookies: These are essential to allow you to browse a platform and use its features.

• Performance Cookies: they collect information about how you use the Galeazzi platform and serve to improve your navigation and improve your experience. The information collected includes, for example, the internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, the average duration of the visit and the pages viewed.

• Functional Cookies: Allow the platform to remember your choices (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features.

• Advertising Cookies: They track your browsing habits and are used to deliver targeted advertising. These cookies also limit the number of times you see an ad and measure the effectiveness of advertising campaigns. They also remember if you have ever visited a website and this information is shared with other organizations such as advertisers.

Galeazzi uses necessary and performance cookies. You may, at any time, disable Cookies through your browser settings, installing plug-ins available on the market, or even making use of other technologies that you deem necessary. In addition to cookies, Galeazzi uses other tracking technologies, such as:

• Web Server and Platform Records: Galeazzi's servers automatically collect certain information to assist, administer and protect the services offered, as well as to analyze usage and improve your experience. The 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 a third party; device operating system and other technical data; city, state and country from where you are accessing the platform, including for fraud prevention; typed information or texts; and clicked links and buttons.

• Connections via Social Networks: Some of Galeazzi's services may include social networking features, such as Facebook “Like” buttons and widgets; “Share” button and interactive mini-programs.

Galeazzi may allow you to choose to use logins from its own social networks to access some of the services offered, in which case Galeazzi may receive and store authentication information for these services.

9. Contact Information

Doubts, comments, suggestions and/or complaints regarding this Policy, as well as any need for information, alteration or deletion of personal data, must be sent to our Data Protection Officer (“Instructor” or “DPO”). Our DPO is The Netbynet IT Team and can be contacted at This email address is being protected from spambots. You need JavaScript enabled to view it..

10. Changes

Galeazzi seeks constant updates and improvements. Therefore, we reserve the right to review the content of this Policy from time to time, in particular to adapt it to new legal provisions and technical developments, so that we can also safeguard data protection in the future.

In the event that Galeazzi changes this Policy in the future, you will receive a notice 30 (thirty) days in advance via the registered email address.

Galeazzi advises you to periodically read this Policy in order to keep up to date with its content. This version of this Policy was last updated on 06/18/2021.

11. Legislation and forum

This Policy will be governed, interpreted and executed in accordance with the laws of the Federative Republic of Brazil, regardless of the conflicts of these laws with the laws of other states or countries, and the São Paulo District Court is competent to resolve any doubts arising from this instrument, with the resignation of any other, however privileged it may be.

Office

  • Avenue Brigadeiro Faria Lima, 2081 - 10º to walk

  • Pinheiros, São Paulo - SP

  • CEP: 01452-001

Contacts

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