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PRIVACY POLICY

This is a free translation from Portuguese to English. The original version in  Portuguese prevails for all purposes.

 

LUCCE PARTNERS ASSESSORIA LTDA ("LUCCE" or "Company") is committed to respecting the privacy of the information and personal data ("Data") provided by you, the data subject ("Data Subject"). Therefore, LUCCE has developed this Privacy Policy ("Policy") to describe how it collects, stores, and uses your Data, in accordance with Brazilian Law 13.709/18, the General Data Protection Law ("LGPD").

1. What Data Can We Collect?

1.1. Data Provided Directly by the Data Subject: The Data processed by LUCCE may be provided directly or indirectly by the Data Subject. No Data will be used in a discriminatory, abusive, or unlawful manner. LUCCE will ensure the integrity and confidentiality of all Data it collects. You may provide your Data directly to us, for example, but not limited to, through (i) submitting a resume for participation in a selection process; (ii) signing up on our website to receive a newsletter; (iii) contacting us via our website or the contact email provided; or (iv) a contractual, labor, or corporate relationship with LUCCE. When sending Data to LUCCE, whether through any of the aforementioned methods or others not listed, it is important that you are fully aware that your Data will be stored and processed by LUCCE for the necessary purposes. 

1.2. Data Collected Indirectly: LUCCE may collect your Data indirectly in the following situations, but not limited to: (i) receiving documentation necessary for the analysis of potential transactions, such as, for example, but not limited to, corporate information of companies and data about their employees, such as directors, advisors, partners, or shareholders; and (ii) receiving information from clients, along with the corresponding due diligence, as applicable, for internal record-keeping. To the extent of its responsibilities, LUCCE makes every effort to ensure that the Data Subject, when providing their Data to a partner who may share it with us, is aware of this, even if this Data is provided indirectly. Furthermore, LUCCE ensures that the partner follows procedures compliant with the LGPD. 

1.3. Considerations on Sensitive Personal Data: LUCCE, as of the date of publication of this Policy, has not collected, nor does it intend to collect or process sensitive personal data. If such data is voluntarily provided by a Data Subject, it will be processed in an exceptional manner and in accordance with the provisions of the LGPD.

However, if LUCCE begins to collect sensitive data on a regular basis, this Policy will be adapted to comply with the specific rules set forth in the LGPD for the processing of such data.


1.4. Considerations on Personal Data of Children and Adolescents: The collection of Data from children and adolescents will occur specifically to fulfill legal obligations and execute contracts between LUCCE and its Employees. This Data is provided by their parents or legal guardians with consent, as required by the LGPD.

2. What Do We Do with Your Data?

LUCCE may use your Data for commercial actions such as sending event invitations, communicating the launch of new products and services, or, in the case of clients and former clients, sending periodic reports on M&A activity, debt, or sending other information and access credentials to communication portals, depending on your relationship with LUCCE.

However, it is important to note that there will always be an option to unsubscribe from receiving emails with this type of content, if you no longer wish to receive communications or information from LUCCE.

Depending on the type of relationship you establish with LUCCE, your Data may also be used for (i) conducting due diligence; (ii) complying with legal and/or regulatory requirements; (iii) conducting commercial or negotiation practices inherent to LUCCE’s activities; among other lawful activities related to the regular exercise of LUCCE’s activities, as outlined in its corporate purpose. 

In addition, for the execution of our financial advisory activities, it may be necessary to share information with other service providers involved in the transaction, such as legal, accounting, payment, controller, custody, commercial advisors, and also specialized consultants in administrative, financial, research, security matters, among others (“Service Providers,” see item 5 below). 

If you would like to receive more specific information about the use of your Data, please contact us via email at contato@luccepartners.com. 

3. How Do We Store Your Data? 

Your Data is stored in LUCCE’s private network and allocated in proprietary directories specific to the internal area of the Company responsible for the relationship, with access protected by an authenticated Employee ID and personal password. 

In this regard, to protect your Data, the highest standards of technological and physical security are adopted to prevent loss, misuse, unauthorized access, alteration, and destruction of the data.

Your Data will be stored for as long as necessary, according to the purpose for which it was collected by LUCCE. The purpose and respective storage period will be assigned to each Data collected by LUCCE. To obtain this information about your Data, please request it through the LGPD Channel, as outlined in item 7 of this Policy. 

4. Data Sharing

The circumstances for data sharing will depend on the nature of your relationship with LUCCE. Data sharing will only occur when necessary for the regular exercise of LUCCE’s activities, as mentioned in this Policy.

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4.1. Service Providers: Occasionally, your Data may be shared with Service Providers so that LUCCE can achieve the purpose for which your Data was collected. Service Providers undergo a due diligence process until their final approval and possible hiring by LUCCE, which includes aspects related to the process of the Data. It is also worth mentioning that sharing the Data with third parties will always comply with the provisions of this Policy, as well as applicable regulations and legislation.

4.2. Companies in the Same Economic Group/ Affiliate/ Associate and Controlled Companies: Your Personal Data may be shared with controlled, affiliated, or companies within the same economic group as LUCCE, for the purposes mentioned in this Policy. If this occurs, the procedures will comply with the provisions of this Policy, as well as applicable regulations and legislation.


4.3. Disclosure of Data for Legal Reasons: Depending on the situation, and whenever permitted, in accordance with the transparency principles adopted by LUCCE, this will be communicated to the Data Subject in advance. 

5. Your Rights as a Data Subject

You may, at any time, request through the LGPD Channel: 

  1. confirmation of the existence of Data stored by LUCCE and access to this Data; 

  2. correction of incomplete, inaccurate, or outdated Data;

  3. anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed Data under the LGPD; 

  4. information about the possibility of not providing your consent for the processing of any of your Data and the negative consequences of this action; 

  5. revocation of consent for the processing of any Data; and 

  6. ny other actions provided under the LGPD or granted by applicable laws or regulations. 

LUCCE will always make every effort to comply with your requests, unless they are not feasible due to legal, regulatory reasons, or due to the nature of the relationship established between you and LUCCE. 

In any case, all responses to requests made through the LGPD Channel, whether positive or negative, will always be clear and substantiated. 

6. LGPD Channel

You may exercise any of the rights described in item 6 above, or clarify any doubts regarding the processing of your Data by LUCCE, through the LGPD Channel, which can be accessed via email contato@luccepartners.com or by phone (11) 3168-2805. 

Your request, depending on the complexity of its content, may be responded to immediately or within the maximum timeframe provided by the LGPD.

7. Updates to this Policy

LUCCE reserves the right to change the way it processes Data at any time and whenever necessary, to adapt to its activities and improve the execution of its services. In this case, this Policy will be updated on our website.

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