Privacy Policy
This website https://www.brunel-partners.com.br/ ("Site") is maintained and supported by Brunel Consultoria de Negócios e Investimentos Ltda.
Your privacy is important to us. This privacy policy explains Brunel's personal data processes, how Brunel processes it and for what purposes.
We collect and use some of your personal data through our interactions with you and through our services.
Pursuant to Federal Law No. 13,709/2018, the General Personal Data Protection Law ("LGPD"), we act as the controller of your personal data.
Read the specific details of the services in this privacy policy, which provides relevant information about:
What data we collect and how we use it;
Your rights in relation to your personal data; and
How to contact us.
1. Data we collected and reasons for collection
Our Site collects and uses some of your personal data in accordance with the provisions of this section.
Your data is collected transparently and for the following purposes:
Validate our clients' registration information and keep it up to date;
Enable the provision of our services in a customized and appropriate manner, including registration, enabling transactions, permissions and the feasibility of executing contracts;
Answering requests and contacts, receiving complaints, investigating complaints or responding to requests from our clients and any other parties involved in the transaction;
Relationship management with our clients, including communication via direct marketing, advertising and promotional actions;
Legitimate exercise of our rights, including in the context of contracts and judicial, administrative or arbitration proceedings, as well as to comply with our legal and regulatory obligations; and
Respond to government authorities, including, but not limited to, the Brazilian Securities and Exchange Commission ("CVM"), within the scope of judicial or administrative communications and proceedings, in compliance with our legal, regulatory or any other duties that may be required of us[MC@P1] . or any others that may be required of us[MC@P1] [GVBG2] .
1.1 Sensitive data
We do not collect sensitive data from our users, as defined in art. 5, II of the LGPD. Thus, no data will be collected on racial or ethnic origin, religious conviction, political opinion, union membership religious, philosophical or political organization, data relating to health or sex life, genetic or biometric data, when linked to a natural person.
1.2 Personal data expressly provided
We collect the following personal data that is expressly provided by you:
by filling in the contact form available on our website:
Full name; and
E-mail address.
1.3 Collection of data not expressly provided for
Occasionally, other types of data not expressly provided for in this Privacy Policy may be collected, provided that they are provided with your consent, or that the collection is permitted on legal grounds.
We may collect information about you that is publicly available or that has been made public by you, as well as information about mentions of or interactions with Brunel, whether through testimonials posted on profiles and pages on networks or searches on search engines. or searches on search engines, such as:
1.4 Sharing personal data with third parties
In order to fulfill the purposes indicated in item 1.1 above, Brunel may also collect personal data from various third parties, which may be marketing or commercial partners (such as family offices)[GVBG3] , cybersecurity companies, among others. cybersecurity companies, bureaus, anti-fraud companies, among others.
In any case, you can request that Brunel inform you how it received your personal data.
Brunel does not use your personal data to commercialize it or share it for profit or economic purposes. However, we do share some of the personal data mentioned in this section with third parties. Your may be shared:
with competent judicial, administrative or governmental authorities, whenever there is a request, requisition or court order. Your data may also be shared with judicial and administrative authorities and entities whenever it is necessary for Brunel to present a defense or promote the regular exercise of a right, as well as for compliance with legal or regulatory obligations;
with data operators, which are partner companies that provide services to Brunel; and
for the purpose of fulfilling the purpose of our activities, including, but not limited to, sharing data with asset managers.
You can request that Brunel inform you with which third parties it has shared your personal data.[MC@P4] [GVBG5]
Whenever personal data is shared, we will take all measures available and within our reach to ensure that all information security standards are observed, with strict observance of the purposes described herein.
2. How long will your personal data be stored?
Following the guidelines established by the Brazilian Securities and Exchange Commission in CVM Resolution No. 50, of August 31, 2021, and in compliance with the purposes and legal justifications for processing the data, we inform you that the personal data we collect will be stored and used for a period of 5 (five) years.
In other words, if there is a legal or regulatory justification, the data may continue to be stored even if the purpose for which it was collected or processed has expired.
3. User rights
You can also make choices about the collection and use of your data, obtaining it at any time and upon request:
Confirmation of the existence of treatment;
Access to data;
Correction of incomplete, inaccurate or outdated data;
Anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of the law;
Deletion of personal data processed, except in cases provided for by law;
Information on public and private entities with which we share data;
Information about the possibility of not providing consent and the consequences of refusing; and
Revocation of consent, when the data has been processed on the basis of the data subject's consent.
It is important to note that, under the terms of the LGPD, your consent is enough to delete your personal data, unless the data becomes unnecessary, excessive or is processed in breach of the law.
3.1 How you can exercise your rights
Please be aware that we will facilitate the exercise of your rights whenever possible and to the fullest extent of the law. We have a specific communication channel to manage communications with data subjects and enable you to exercise your rights. rights. You can make any complaint, request or request for information relating to the processing of your personal data through the channel indicated in item 7 below.
In order to ensure that you are in fact the owner of the personal data that is the subject of the request, we may ask you for documents or other information that can help us identify you correctly, in order to protect our rights and the rights of rights of third parties. This will only be done, however, if it is absolutely necessary, and you will receive all related information.
4. Security measures in the processing of personal data
We employ technical and administrative security measures to protect personal data from unauthorized access and from destruction, loss, misplacement or alteration.
The measures we use take into account the nature of the data, the context and purpose of the processing, the risks that a possible violation would generate for your rights and freedoms, and the standards currently employed in the market by companies similar to ours. by companies similar to ours.
We have adopted the following security measures:
Storing only hashed passwords;
Use of a password safe;
Cryptography;
Access restricted to people who need access to the data and who have been previously and duly [MC7] authorized in accordance with applicable legislation - MFA, or Multi-Factor Authentication, represents an advanced security technique that asks users to prove their identity through two or more forms of authentication before granting access to an account or system;
All our employees are subject to confidentiality obligations;
Access monitoring - we have established the blocking of access to e-mail accounts associated with the brunel-partners.com.br domain for users who attempt to access it from outside Brazilian territory. This measure is essential because, by restricting access exclusively to users located in Brazil, we will be able to mitigate more than 90% (ninety percent) of incidents related to e-mail intrusions;
Vulnerability Management - in order to access accounts under the brunel-partners.com.br domain, users' devices must meet certain security prerequisites. These include: activation of BitLocker, presence of antivirus, activation of the Windows firewall and secure boot, among others. This measure will add an extra layer of protection to our network environment, ensuring the integrity and confidentiality of corporate information.
We therefore follow high technical standards of information security in order to be able to protect our users' personal and non-personal data.
However, even if we do everything in our power to prevent security incidents, it is possible for a problem to occur that is caused exclusively by a third party - such as in the case of hacker or cracker attacks or, or in the event of the sole fault of the user, which occurs, for example, when you yourself transfer your data to a third party. Thus, under the terms of Article 43 of the LGPD, although we are responsible for the personal data we process, we are exempt ourselves from liability in the event of an exceptional situation such as this, over which we have no control whatsoever.
In any case, should any type of security incident occur that could generate significant risk or damage to any of our users, we will notify those affected and the National Data Protection Authority ("ANP") of the incident, in accordance with the provisions of the LGPD.
5. Complaint to a control authority
Without prejudice to any other administrative or judicial remedy, if you feel in any way wronged, you may lodge a complaint with the ANP.
6. Updates and changes to this policy
This version of this Privacy Policy was last updated on: 07/11/2023 (November 7th, two thousand and twenty-three).
We reserve the right to modify this policy at any time, in particular to adapt it to any changes made to our Site, either by making new features available or by removing or modifying existing ones.
7. How to contact us
If you have any questions about this Privacy Policy or the personal data we process, please contact us through one of the channels mentioned below:
E-mail: adm@brunel-partners.com.br
Phone: +55 11 3360-5514
Postal address: 05416-000