MAIN ITEMS OF THIS POLICY
> ho are we? Europartner acts as a personal data Controller, defining its purposes and processing
> Data Processing We use Personal Data strictly necessary to provide our services and for our operations and business purposes.
> Subject rights Personal Data Subjects have several rights granted by the LGPD that are fully guaranteed by Europartner.
> Person in Charge If you have any questions or if you want to exercise your rights, please contact us at “[email protected]”.
All those who work with or for Europartner have a level of responsibility related to the Processing of Personal Data in the performance of their activities, each of whom is responsible for observing and enforcing this Policy and all the principles of the LGPD.
Among the main responsibilities and tasks we can mention:
will need to demonstrate a commitment to ethics and integrity, lead by example, emphasize the importance of the topic and support all necessary actions to implement an effective data protection and privacy program.
The PERSON IN CHARGE (“DPO”)
will act to monitor that Europartner is in compliance with the LGPD, acting as a communication channel between the company, the Data Holders and the ANPD.
The PRIVACY AND DATA PROTECTION CRISIS COMMITTEE (“CCPPD”)
will act for the purpose of examining, advising and adopting measures aimed at mitigating problems that may arise as a result of violation of the precepts of the LGPD.
must commit to the best information security practices following Europartner’s guidelines, in adopting measures such as: (i) using secure and strong passwords that must not be shared; (ii) do not share data with unauthorized persons; (iii) update the data and delete it when no longer needed; (iv) and other measures defined by Europartner.
PERSONAL DATA PROCESSED, PURPOSES AND LEGAL BASIS
Europartner undertakes to limit the processing of Personal Data to what is strictly necessary for its activities and in accordance with the provisions of the Applicable Data Protection Laws, as described below.
Europartner processes data for the purpose of (i) executing contracts with customers, (ii) registering financial operations in Brazil, (iii) managing cash flow, (iv) complying with legal obligations and/or regulatory, and activities related to Human Resources.
The Data processed by Europartner, as well as its purposes and its retention and deletion will be informed in the Data Retention and Disposal Policy.
Cookies have several purposes, among which we can highlight: (i) Necessary Cookies: Allow security and accessibility settings; (ii) Analytical Cookies: collect data so that it is possible to issue statistical reports on the websites user preferences; (iii) Marketing Cookies: to target ads and advertising according to your preferences, for more assertive communication.
Europartner emphasizes that its Website may contain access links to other external sites, whose content and privacy policies are not the responsibility of Europartner. Therefore, it recommends that, when redirected to external sites, users always check the respective privacy policies before providing their data or information.
Unless Europartner under a legal or court order, user information is never transferred to third parties or used for purposes other than those for which it was collected by Europartner.
Europartner may share Personal Data with service providers, as well as software and systems providers, for the purposes of register management, documentation and other necessary measures.
And may also share Personal Data with business partners (national and international), correspondents, paralegals, immigration service providers, auditors, accountants, translators and others, when necessary to assist in the legal activities provided by Europartner.
For any and all forms of sharing, the legal determinations and procedures necessary for the process to take place legitimately will be respected. In the case of international data sharing, Employees must comply with the need to prepare and sign contracts or terms of commitments containing personal data protection clauses.
PERSONAL DATA SECURITY
Europartner will adopt, under the terms of the LGPD, security, technical and administrative measures capable of protecting Personal Data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication or any form of inappropriate or illicit Processing, implementing, if necessary, additional security means appropriate to the technical standards set forth in the future by the ANPD.
Among the measures currently adopted by Europartner to guarantee the security of its servers and systems, we can mention: (i) that all accesses are carried out via VPN – Virtual Private Network; (ii) that access is made through an administrator login and password; (iii) segmentation by sector is carried out.
All Personal Data provided will have its access limited to agents qualified and duly authorized to process it. Europartner undertakes to notify the ANPD and the Holder in the event of any security incident that may cause significant risk or damage to Holders.
Europartner will store personal data throughout the period of Processing, through digital means, such as email, Whatsapp, Prosoft, folders on the Europartner server, Excel, communication platforms and through physical means, after which they will be discarded. and/or anonymized (except for those that are kept as required by law), in compliance with article 16 of the LGPD.
Subjects’ Personal Data will not be kept in the Europartner database for longer than necessary for the purposes for which they were collected or otherwise processed, subject to the legal permissions and restrictions on the subject.
For this, Europartner will periodically analyze, through its Person in Charge, the database maintained, with due evaluation of the justifications presented by the areas, in order to avoid situations of Excessive, unnecessary Personal Data Processing or treated in violation of the legislation.
RIGHTS OF DATA HOLDERS
The holders of Personal Data will be guaranteed all applicable rights, in the form of articles 17 and 18 of the LGPD, in accordance with legal requirements, whose service will be provided by the Person in Charge with the support of the Privacy Committee. Which are: (i) Confirmation of the Existence Processing; (ii) Access; (iii) Correction; (iv) Anonymization, blocking or deletion; (v) Information; (vi) Information on Failure to Provide Consent; (vii) Withdrawal of Consent; and (viii) Opposition.
These rights can be exercised by contacting Europartner at the following address:[email protected] indicating the subject of the request and attaching proof of identity, as well as any information needed in order to process the request. Europartner will process requests as quickly as possible and in accordance with the LGPD, within a maximum period of fifteen days.
In case of violation of this Policy, the facts will be investigated and disciplinary or corrective measures will be applied, in proportion to the severity of the event, in compliance with labor and civil legislation and safeguarding the right to full defense and adversarial proceedings.
PERSON IN CHARGE INFORMATION
In case of doubts and/or requests in relation to Privacy and Data Protection, please contact Europartner’s Person Responsible for Processing Personal Data, by email:
Name: Antoine Reymondon
E-mail: [email protected].