Privacy Policy & Cookies

PUPPE SOCIEDADE DE ADVOGADOS ("MPUPPE"), a legal entity governed by the laws of Brazil, registered under CNPJ 1.632.008/0001-58, headquartered at Condomínio Prive Morada Sul Etapa C, CJ30 casa 16, Bairro SHJB, Brasília/DF, CEP: 71680-348 ("MPUPPE"), considers the protection of data and the privacy of its Clients, Collaborators and Partners of the utmost importance and adopts systems and measures in its business aimed at protecting the security and integrity of all such information.

Thus, this Privacy Policy forms part of MPUPPE's governance framework and was drawn up in compliance with Law 13,709/2018 (General Data Protection Law; "LGPD") and as a commitment to the protection of personal data ("Personal Data") of all those who access this website or use our services as clients or collaborators ("Clients and Partners"), or who in any way have their personal data processed by us. In addition to the LGPD, MPUPPE undertakes to comply with the provisions and requirements of Regulation (EU) No 2016/679 and 2018/1725, as well as Directive (EU) 2016/680, comprising the General Data Protection Regulation of the European Union (GDPR), in order to guarantee a similar level of protection for data processed in Brazil of Users, Clients and Partners from member states of the European Union and/or other countries.

In this way, the processing of personal data will take place within the terms described in this Policy and in accordance with the principles of the LGPD and GDPR. We have drawn up this Policy as a means of preserving your privacy, ensuring that your personal data will be processed in accordance with Brazilian legislation and best market practices, and to help you understand how we collect, store, share and protect the personal information you provide to us.

Accordingly, MPUPPE reaffirms its commitment to acting in accordance with the principles of purpose, adequacy, necessity, free access, quality, transparency, security, prevention, non-discrimination, accountability and ethics, in order to uphold privacy and ensure the confidentiality of the Personal Data of all Users, Clients and Partners.

1) General Information

MPUPPE is a law firm specializing in the provision of strategic, advisory and contentious legal services for companies, startups, funds, investors and public and private sector organizations, with a multidisciplinary focus on Digital Law.

When you access our website, we automatically receive your computer's internet protocol address (IP address) in order to obtain information that helps us learn about your browser and operating system.

This Policy is continuously updated in relation to new technologies, commercial practices and market needs. For further information, or if you have doubts or concerns, or wish to request the deletion or rectification of your data, please contact us via e-mail at privacidade@mpuppe.com

2) Principles and Guidelines

Our use and sharing of your data, follows the guidelines and principles of Law 13,709/2018 (LGPD), specifically:

In addition to these, the following guidelines also inform this Policy:

  • Only the data genuinely necessary for the purpose to which it is intended and its processing shall be collected;
  • MPUPPE will not sell your data, but may share your personal information or make it available to partner companies or other companies that work directly with MPUPPE, in order to improve your experience as a website user, client or collaborator, or to partners oriented towards the same purposes and principles set out in this Policy.

3) Fundamental Concepts

Below are some fundamental concepts for understanding this Policy and the LGPD, as well as the processing carried out on your personal data:

Data SubjectThe natural person to whom the personal data that are subject to processing relate.
Data ProcessingAny operation carried out with personal data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
Sensitive DataPersonal data concerning racial or ethnic origin, religious belief, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person.
Personal DataInformation relating to an identified or identifiable natural person, such as name, national ID, tax identification number, e-mail and telephone;
LGPD (General Data Protection Law)On 14 August 2018, Law 13,709/2018, the General Data Protection Law, was published, responsible for regulating the processing of personal data in order to protect the fundamental rights of freedom and privacy and the free development of the personality of the natural person. This policy takes the LGPD into account; however, should a new law or other laws, normative decrees or other binding rules be enacted, we reserve the right to adjust this policy to meet any new requirements.
ProcessorAn agent that processes personal data on behalf of the Controller, for example, vendors.
ControllerThe agent responsible for decision-making regarding the processing of personal data.

4) To whom does this privacy policy apply?

It applies to all those whose data is processed by MPUPPE including, but not limited to, users of our website, clients, collaborators, suppliers and business partners of MPUPPE.

5) What types of personal data do we collect and how do we use it?

MPUPPE collects your information in various ways, including our website, participation in selection processes, hiring and interactions on social media. The personal data collected, such as name, tax identification number, address, telephone and email, are used to create and manage contracted services, to improve the User experience and to fulfill legal obligations, ensuring the protection of Users.

The collection of personal data from collaborators, employees, suppliers and business partners may also occur through direct contact between the data subject and MPUPPE, as well as through professional social media networks and intermediation by specialized companies. The information that may be requested includes: name, e-mail, address, telephone, tax identification number, national ID, profession, date of birth, marital status and financial data.

The processing of personal data may occur for the following non-exhaustive purposes:

  1. Improve service
  2. Respond to requests more efficiently;
  3. Personalize the user experience;
  4. Use the feedback you provide to improve our products and services;
  5. Run promotions, contests and surveys;
  6. Send you information you previously agreed to receive, on topics we believe to be of interest to you;
  7. Perform obligations agreed in a contract;
  8. Comply with legal obligations;
  9. For other purposes for which we provide specific notice, or otherwise as authorized or required by law.

6) What are legal bases for the processing of your personal data?

We process your personal information on the basis of various different legal grounds, primarily:

Consent: We may carry out processing on the basis of your consent. In such cases, you may withdraw it at any time, without affecting the lawfulness of prior processing. Providing your consent is voluntary. Acceptance of the terms of this Privacy Policy and continued use of our website implies consent to the processing, use and eventual sharing of your information.

Performance of a contract: We may process your personal information as necessary to fulfill or perform contractual obligations.

Exercise of legal rights: Your data may be used for the conduct of legal proceedings, for example in civil and advisory matters.

Legitimate Interest: We may process your personal information as necessary to pursue our legitimate interests. In such cases, we will ensure that our interests do not override your fundamental rights and freedoms that require the protection of personal data.

Legal obligations: We may process your personal information as necessary to comply with relevant laws, regulatory requirements and to respond to legal requests, judicial or administrative orders or legal proceedings.

7) What are the rights of data subjects?

The LGPD provides for the rights that you, as the data subject, may exercise by means of a formal request to MPUPPE via our e-mail. These are:

  • Access to personal data;
  • Anonymization, blocking or deletion of unnecessary, excessive or non-compliant data;
  • Confirmation of the existence of processing;
  • Correction of incomplete, inaccurate or outdated data;
  • Right to object to processing, if irregular;
  • Deletion of personal data processed with the data subject's consent;
  • Information on the possibility of not providing consent;
  • Information on the entities with which the controller has shared data;
  • Portability of data to another service or product provider;
  • Review of automated decision-making;
  • Revocation of consent.

MPUPPE will have 15 (fifteen) business days to respond to data subject requests, and such requests will be assessed in accordance with the provisions of the LGPD.

For legal reasons, some requests may not be fulfilled in cases of:

  • Compliance with a legal or regulatory obligation by the controller;
  • Compliance with a contractual obligation;
  • Existence of a contract that is valid and in force;
  • Existence of a legal determination regarding minimum data retention periods.

8) Sharing of personal data with third parties

We may share your personal data with partner companies, collaborators, third-party companies responsible for providing employee benefits, or business partners who assist us in providing services, products and benefits, as well as in the administration of our services. These parties will always be informed of the requirements relating to the processing of your data, keeping it secure and complying with the law, and will be subject to external audits, public bodies or official authorities for the fulfillment of legal obligations.

In general, third parties authorized by us will only collect, use and disclose your information to the extent necessary to enable them to perform the services they provide to us. However, be aware that certain parties, such as payment gateways and other transaction processors, have their own privacy policies.

We therefore recommend that you read the respective privacy policies of these third parties so that you can understand how your personal information will be used by them. In particular, note that certain providers may be located or have facilities located in different jurisdictions. Thus, if you wish to proceed with a transaction involving the services of a third-party provider, your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

Example: if you are located in Brazil and your transaction is processed by a gateway located in the United States, your personal information used to complete that transaction may be subject to disclosure under United States legislation, including the Patriot Act. If the provider or the facilities are located in the European Union, the transaction will be governed by the GDPR.

Once you leave the MPUPPE website or are redirected to a third-party application or website, you will no longer be governed by this Privacy Policy or our website's Terms of Service. Thus, when you click on links, they may direct you to an address outside our website. We are not responsible for the privacy practices of other websites and encourage you to read their privacy statements.

9) How long will my personal data be retained?

Your personal data will be stored for as long as necessary to fulfill the purpose for which it was collected. We may retain your personal information for longer if it is necessary to comply with court orders or contractual or legal obligations, or if it is in any other way relevant to future legal or judicial events, as well as internal investigations and the fulfillment of other obligations by MPUPPE.

10) Use of Cookies

MPUPPE adopts a specific cookie policy and may collect cookies on its portals. In brief, a cookie is a small amount of data sent from a web server to your browser and stored on your computer's hard drive. We use cookies to understand how our websites are used, which helps us improve your online experience in our environments.

In most internet browsers, you can delete them from your computer's hard drive, block them or receive a warning before a cookie is stored on your computer. Please consult your browser's instructions for more information.

We use the following types of cookies:

  • Necessary cookies: These are essential cookies that do not require consent.
  • Analytics cookies: These are non-essential cookies controlled by the cookie banner.
  • Advertising cookies: Advertising cookies are ad pixel cookies.
  • Third-party system cookies: These are cookies created by third-party companies, i.e., different from the company whose website you are visiting.

On our website, you can find and manage your cookie preferences through our cookie notice available on our homepage.

The website stores cookies. These are used to collect information about your interaction with it. This information is used to personalize your experience and for metrics. For more information, please read our Cookie Policy. If you refuse, your information will not be tracked. A cookie will be used to remember your preference not to be tracked.

11) Disclosure

We reserve the right to disclose your personal information if we are required to do so by order, as a result of a judicial or administrative order, to fulfill a contractual or legal obligation, at the request of the bodies responsible for data protection, or if you violate our Policies.

12) Information Security

In order to protect your personal information, we take reasonable precautions, including physical, governance, compliance, organizational and technological measures, to ensure that it will not be lost, misappropriated, accessed, disclosed, altered or destroyed inappropriately.

Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all standard requirements generally accepted by the industry and considered best practices in data protection.

In addition, we apply appropriate data collection, storage and processing practices and security mechanisms to protect your data against unauthorized access, alteration, disclosure or destruction.

We guarantee that the protection of your personal data is one of our priorities and that, should any incident occur, we will take all possible measures to minimize potential damage.

13) Contact us

If you have any questions about this Privacy Policy or any requests regarding the processing of your personal data or the rectification or deletion of your data, please contact our Data Protection Officer (DPO) via e-mail at privacidade@mpuppe.com

14) Privacy Policy Updates

We reserve the right to modify this Privacy Policy at any time, to better serve the needs of Users, Clients and Partners. As such, we reserve the right to alter this document at any time. These changes may be made without prior notice; therefore, we encourage you to check this Privacy Policy periodically to verify possible changes to its content. Please review it frequently.

Changes and clarifications will take effect immediately upon publication on the website. If we make material changes to this policy, we may notify you of the updates, so that you are aware of what information we collect, how we use it, and under what circumstances we use and/or disclose it.

If our company is acquired, receives investment or merges with another company, your information may be transferred to the new owners so that we can continue to offer you products and services, and a new Policy may be adopted.

15) Data Protection Officer (DPO)

To ensure compliance with the LGPD and protect your personal data, MPUPPE has appointed a Data Protection Officer (DPO). The DPO is responsible for acting as the point of contact between the CFOAB, data subjects and the National Data Protection Authority (ANPD).

Data Protection Officer (DPO): Matheus Puppe

Contact: privacidade@mpuppe.com

The DPO is available to answer questions, respond to requests and ensure that your personal information is handled securely and in compliance with current legislation.

Cookie Policy

We use cookies to improve performance and the user experience on our website.

What are cookies?

Cookies are small text files that a website, when visited, places on the user's computer or mobile device via the internet browser. The placement of cookies will help the website recognize your device on a future visit. We use the term cookies in this policy to refer to all files that collect information in this way.

The cookies used do not collect information that identifies the user. However, if you are already our client, we may monitor your visits to the website, provided that at least once you have started browsing from a communication sent by us, for example, by SMS or e-mail.

Cookies also collect generic information about how clients access and use the websites or the country/countries from which they access the site, etc.

Cookies only retain information related to your preferences.

At any time, the User may, through their internet browser settings, choose to be notified about the receipt of cookies and block their entry into their system.

Refusing to use cookies on the website may result in the User being unable to access some of its areas or receive personalized information.

What are cookies used for?

Cookies are used to help determine the usefulness, interest and number of uses of websites, allowing faster and more efficient navigation and eliminating the need to repeatedly enter the same information.

What types of cookies do we use?

Our cookies serve different purposes:

Essential cookies — Some cookies are essential for accessing specific areas of our website. They enable navigation on the website and the use of its applications, such as accessing secure areas of the site via login and form submissions. Without these cookies, some services cannot be provided.

Analytical cookies — We use these cookies to analyze how Clients use the website and to monitor its performance. This allows us to provide a high-quality experience to Clients by personalizing our offering and quickly identifying and correcting any problems that arise. For example, we use performance cookies to find out which pages are most popular, which method of linking between pages is most effective, or to determine why some pages are displaying error messages. Based on site usage, we may also use these cookies to highlight articles or services on the site that we think may be of interest to clients. These cookies are used solely for the purposes of creating and analyzing statistics, without ever collecting information of a personal nature.

Functional cookies — We use functional cookies to remember user preferences. For example, cookies avoid the need to type the user's name each time they access the site. We also use functional cookies to provide advanced services to the user, such as posting comments on an article. In summary, functional cookies store the user's preferences regarding the use of the website, so that it is not necessary to reconfigure the site each time they visit.

Third-party cookies — These are used to measure the success of applications and the effectiveness of third-party advertising on our website.

Advertising cookies — These are used to direct advertising based on each user's interests and the number of visits they have made, allowing the number of times an advertisement is displayed to be limited. These cookies help measure the effectiveness of advertising.

The cookies we use may be:

Permanent cookies — These are stored at the internet browser level on your access devices (PC, mobile and tablet) and are used whenever the user makes a new visit to the website. They are generally used to direct navigation according to the user's interests.

Session cookies — These are temporary and remain in your internet browser's cookies until you leave the website. The information obtained allows problems to be identified and a better browsing experience to be provided.

After authorizing the use of cookies, the user can always disable some or all of our cookies.

All browsers allow the user to accept, refuse or delete cookies by selecting the appropriate settings in the respective browser. As a rule, you can configure cookies in the "options" or "preferences" menu of your browser.

Please note that, by disabling cookies, parts of our website may not function correctly, partially or fully affecting your browsing experience.

In the event of any doubt regarding the provisions of this Privacy and Data Processing Policy, please contact us via e-mail at privacidade@mpuppe.com