Privacy Policy

This Privacy Policy describes the practices of Assolari e Ortolan Advogados, headquartered in the City of São Paulo, at Rua Araguari, 835, 3rd floor, Moema, CEP 04514-041, enrolled in the National Register of Corporate Taxpayers (the “CNPJ”) under No. 23.554.516/0001-83, registered with the Bar Association of São Paulo – OAB/SP on September 30, 2015, at pp. 331-337, of Book 190 of Companies Register under No. 17241 (“Lassori Advogados”), in relation to the data collected through the website www.lassori.com.br, in accordance with the laws in force and applies to data that identify the user individually (personal data) and other data provided by the user or collected during the use of the aforementioned website. In all cases, Lassori complies with all Brazilian laws and regulations applicable to data protection, especially Law No. 13,709/2018 and Law No. 12,195/2014.

AGREEMENT

1.1. By accessing and/or using the content of the website www.lassori.com.br, the user expresses his full and unreserved acceptance of the terms herein, for all purposes of law. You hereby declare that you agree to this Privacy Policy. If you, the user, do not agree with any of the terms and rules provided for herein, you should not access and/or use the content.

INFORMATION COLLECTED

2.1. Data is collected when entered or voluntarily submitted by users when browsing our website www.lassori.com.br and especially in voluntary registration for our newsletter.

2.2. The information that the website collects from users are: e-mail, name, company, and telephone.

2.2.2. Information considered to be personally identifiable data is that which is collected via user navigation on the website www.lassori.com.br:

– logs
– cookies, through the Google Analytics tool, which collects the following data anonymously and for analytical purposes:

  • language
  • country and city;
  • browser, operating system, and service provider;
  • screen resolution, device type (desktop or mobile), mobile phone model;
  • webpages that the user navigates to within the website, if he is on the website at that time, how the user accessed the website (whether it was via a search engine or directly through the URL of the website), search term that he used on the website, time on the page of the website.

2.2.2.1. You can learn more about Google Analytics in “How Google uses data when you use our partners’ websites or applications”, located at .

2.2.2.2. Any use by Google of user data collected through these tools shall be the sole and exclusive responsibility of Google, and Lassori shall be held harmless from any liability whatsoever.

2.2.2.3. If you do not agree with the data collection by Google Analytics, you can disable it through your browser’s Add-on, available at https://tools.google.com/dlpage/gaoptout?hl=pt-BR.

2.3 It is the user’s duty to provide correct and up-to-date information. We are not responsible for the accuracy, veracity, or lack thereof in the information provided by the user.

2.4 All technologies used by the website www.lassori.com.br will always respect the laws and regulations in force and the terms of this Privacy Policy.

DISCLAIMER

3.1 When browsing the website www.lassori.com.br, the user may be led via hyperlink to content or services, other portals, or platforms that may collect your information and have their own Privacy Policy. External Hyperlinks do not constitute an endorsement by Lassori of the websites/environments linked or the information, products, or services contained therein.

3.2. Lassori does not provide any warranty related to the availability or continued operation of the website www.lassori.com.br. Furthermore, considering the characteristics of the Internet, Lassori does not guarantee the security and privacy of content outside the domain www.lassori.com.br or that it will be uninterrupted, free of viruses or other problems, errors and attacks, and, in particular, it does not guarantee that unauthorized third parties cannot access and potentially intercept, delete, alter, modify, or manipulate in any way the data present on and/or transmitted to its servers.

USE OF INFORMATION

4.1. Lassori may use the data that has been collected and the records of the activities on the website www.lassori.com.br for the following purposes:

  • Contact with potential customers;
  • Statistical analysis of results;
  • Promotion of the services offered;
  • Improvement of services on the website;
  • Improved informed content;
  • Protection of interests in administrative and judicial proceedings;
  • Compliance with a court order or administrative request.

4.2.  The consent regarding the collection of data provided by the user is collected freely, expressly, individually, clearly, specifically, and legitimately.

4.2.1. If the user does not give his consent for the preparation of the test, the services will not be made available to him.

4.2.2. If the user does not give his consent for the optional purposes, related to the sending of information about courses, lectures, and informative material, the services will continue to be provided as normal.

4.3. The user may manage permissions regarding the use of his data through the service channel indicated in item 6.1 below.

4.4. The data collected and the activities registered may also be shared with competent judicial, administrative, or governmental authorities, whenever there is a request, requisition, or judicial order.

4.5. The database formed through the collection of data on the website www.lassori.com.br is our property and responsibility, and its use, access, and sharing, when necessary, will be carried out within the limits and purposes of our business, and may, in this sense, be made available for consultation and assigned to suppliers and authorities, provided that the provisions of this Privacy Policy are complied with.

4.6. Internally, users’ data are only accessed by duly authorized professionals, respecting the principles of proportionality, necessity, and relevance to our objectives, in addition to the commitment to confidentiality and preservation of privacy under this Privacy Policy.

DATA STORAGE AND RECORDING

5.1. The data and activity records collected will be stored in a secure and controlled environment, for a minimum period of six (6) months, under the terms of the Brazilian Civil Rights Framework for the Internet, observing the state of the art available. However, as no security system is foolproof, we are exempt from any liability for any damages and/or losses arising from failures, viruses, or invasions of our database, except in cases of willful misconduct or fault.

5.1.1. Data may be deleted before this deadline if requested by the user.

5.1.2. However, for reasons of law and/or judicial order the data may be kept for a longer period, after which it will be deleted using secure disposal methods.

DATA VIEWING, CORRECTION, AND DELETION

6.1. The user may request the review or rectification of his personal data via e-mail contato@lassori.com.br.

6.2. By the same service tool the User may: (i) request limitation of the use of his personal data; (ii) express his opposition to the use of his personal data, or (iii) request the deletion of his personal data collected and recorded by Lassori.

6.2.1. If the user withdraws his consent for purposes fundamental to the regular operation of the website www.lassori.com.br, the services and features of the website may be unavailable to this user.

6.3 Lassori may, for purposes of auditing, security, fraud control, and preservation of rights, retain the registration history of its users for a longer period of time in the event that the law or a regulatory rule so establishes or for preservation of rights. However, the firm has the option to delete it definitively at its convenience in a shorter period of time, or as requested by the company contracting Lassori’s services.

GENERAL PROVISIONS

7.1. Lassori may change the content of this Privacy Policy at any time, according to purpose or need, as appropriate, for adaptation to and legal compliance with a provision of law or norm that has equivalent legal force, it being the responsibility of the user to confirm it whenever accessing the website www.lassori.com.br.

7.1.1. In the event of significant updates to this document requiring the receipt of consent, Lassori will notify the user via the email provided.

7.2. If you have any questions about the conditions set out in this Privacy Policy or any Lassori document, please contact us through the above service channel.

7.3. If any provision of this Privacy Policy is considered illegal or illegitimate by the authority of the location in which the user resides or that of his Internet connection, the other conditions shall remain in full force and effect.

7.4. The user acknowledges that all communication via e-mail (to the addresses provided by him), SMS, instant messaging applications, or any other digital, virtual, and electronic form are also valid as documentary evidence and are effective and sufficient for the disclosure of any matter relating to the services provided by Lassori, as well as the conditions of provision thereof, except as expressly provided for in this Privacy Policy.

APPLICABLE LAW AND JURISDICTION

8.1. This Privacy Policy and the relationship arising from the actions encompassed herein, as well as any dispute arising hereunder, shall be governed exclusively by Brazilian law.

8.2. The Central Courts of the Judicial District of the Capital of the State of São Paulo are hereby elected to settle any matter involving this document, with the parties renouncing any other, however privileged it may be or may become.

GLOSSARY

For the purposes of this document, the following definitions and descriptions for the best understanding thereof should be considered:

Cookies: are information sent by the website’s server www.lassori.com.br to the users’ computer, to identify it and obtain access data, such as webpages browsed or links clicked, thus allowing one to customize the navigation of users on the website, according to their profile. It is not necessary to accept cookies to browse the website.

Personal Data: Information relating to an identified or identifiable single/individual person who is the data subject. An identifiable person is one who can be identified, directly or indirectly, in particular via reference to an identifier, such as a name, an identification number, location data, electronic identifiers, or one or more specific elements of physical, physiological, genetic, mental, economic, cultural, or social identity.

IP: abbreviation for Internet Protocol. It is an alphanumeric set that identifies users’ devices on the Internet.

Logs: records of users’ activities performed on the website www.lassori.com.br

User: person who accesses or interacts with the activities offered on the website.

Partners, associate lawyers, and trainees of Lassori Advogados are subject to the rules of the profession and to the Code of Ethics and Discipline of the Brazilian Bar Association (OAB), pursuant to Federal Law No. 8,906/1994 (check here).

In addition to the above-mentioned code, Lassori, committed to ethics and integrity, has developed its Code of Conduct with the objective of guiding its professionals in their relations with various audiences.

We are committed to systematically combating corruption, discrimination, and all other forms of misconduct. We do our work with honesty, integrity, and transparency. We respect the legitimate interests of all those with whom we relate.

Our Code of Conduct applies to partners, associates, consultants, contractors, and other members of the firm, without exception, who shall especially observe the following principles:

  • Corporate spirit: conducting one’s professional activities always bearing in mind the general interest of Lassori, which by definition overrides the individual professional interests of each member;
  • Legality: practicing law, in any of its fields, within the limits established by law;
  • No conflict of interest: not accepting a task or cause that may conflict with the interests of clients and the firm itself;
  • Confidentiality: keeping confidential any confidential information and documents which have been transmitted by the client, or which have come to one’s knowledge in the exercise of one’s profession and, in particular, by virtue of one’s position in the performance of one’s professional duties at Lassori;
  • Morality: observing behavior consistent with good manners, sobriety, and courtesy, as well as alert clients and co-workers to situations that may constitute a breach of ethical principles;
  • Transparency: adopting a clear and objective professional posture, subject to the legal cases of confidentiality or reserve necessary to maintain the principle of confidentiality;
  • Exemption: abstaining from associating with clients, except for benevolent purposes and to maintain with clients, without previous knowledge of Lassori, extra-professional business relationships, as well as trading with shares issued by clients;
  • Exactness: taking care of the quality and promptness in the rendering of services and observing legal deadlines strictly.
  • Data privacy: respecting the privacy of personal data of clients and their employees, in accordance with Law No. 1,.709/2018 (click here).

Lassori does not tolerate corrupt practices of any kind. Therefore, it forbids any of its staff from promising, offering, or giving, directly or indirectly, any undue advantage to a public agent or to any third person related to it, with a view to obtaining any undue advantage.

Anti-corruption and anti-money laundering legislation

In the professional performance of all staff members of Lassori, all have the duty to comply with and enforce the anti-corruption rules, notably those set forth in the Brazilian Penal Code and the Anti-Corruption Law (Law No. 12,846/2013). In addition, staff members must respect foreign legislation on the subject, such as the Foreign Corrupt Practices Act (FCPA) in the United States of America and the United Kingdom Bribery Act (UKBA) in the United Kingdom.

Prohibited conduct

Without prejudice to other prohibitions, the following conduct os prohibited:

  • Promising, offering, or giving, directly or indirectly, an undue advantage to a public agent or intermediary, with the intention of obtaining any type of undue benefit for oneself or one’s clients;
  • Facilitation payments, herein understood as a prohibition on offering any advantage to public agents in order to accelerate or favor the performance of official acts, such as obtaining permits, permissions, or other administrative measures;
  • Payment brokerage, herein understood as a prohibition on the brokerage of the delivery of amounts or undue advantages, even at the request of clients, to any public agents or persons related to them, regardless of the reason.
  • Providing or using the personal data of clients, employees, or third parties to which one has had access, without the express consent of the owner, unless it is necessary for the legal exercise of the right.

Lassori’s partners, attorneys, trainees, employees/staff members must also inform the HR department if their spouse, partner, or relative in a straight or collateral line, by blood or marriage, up to the third degree, occupies a position of trust, managerial, or senior management position of any Public Administration body or entity, directly or indirectly, at any level of government.

The conduct guidelines contained in this Code will be brought to the attention of all staff and will also be available at www.lassori.com.br. Any questions regarding compliance with the guidelines set forth in this Code should be addressed to the leader of the area in which the staff member operates or directly to Lassori, through the person of any of its founding partners.

The firm will also receive and investigate complaints about any noncompliance with this Code. Complaints against its staff will be investigated by the Firm, through the person of its founding partners, who will be responsible for applying penalties for non-compliance with this Code, verbal or written warning, suspension, or severance of ties, according to the gravity of the case.

Any deviations from the principles and values established herein can and should be reported by any interested person, whether or not a member of Lassori’s staff and employees, through any of the available reporting channels.

The desire for anonymity or confidentiality of identity is fully and permanently assured, which is intended as a means of motivating reports of violations of this Code.

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