Privacy Policy

SECTION I – GENERAL INFORMATION

This Personal Data Privacy Policy contains information on the collection, use, storage and protection of personal data of users of our website, in order to demonstrate transparency on the subject and clarify to all interested parties their rights and obligations.

This document was prepared in accordance with Law No. 13,709/18 (General Law for the Protection of Personal Data – “LGPD”) and other applicable legislation.

SECTION II – CONCEPTS

For the purposes of this document, the concepts provided for in article 5 of the LGPD apply, transcribed below:

“I – personal data: information related to an identified or identifiable natural person;

II – sensitive personal data: personal data on racial or ethnic origin, religious conviction, political opinion, membership in a union or organization of a religious, philosophical or political nature, data related to health or intimate life, genetic or biometric data, when linked to a natural person;

III – anonymized data: data relating to a data subject who cannot be identified, considering the use of reasonable technical means available at the time of its processing;

IV – database: structured set of personal data, established in one or more locations, in electronic or physical support;

V – data subject: natural person to whom the personal data that is the object of processing refers;

VI – controller: natural or legal person, under public or private law, who is responsible for decisions regarding the processing of personal data;

VII – operator: natural or legal person, under public or private law, who processes personal data on behalf of the controller;

VIII – person in charge: person appointed by the controller and operator to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (ANPD);

IX – processing agents: the controller and the operator;

X – processing: any operation carried out with personal data, such as those referring to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction;

XI – anonymization: use of reasonable technical means available at the time of processing, through which a piece of data loses the possibility of direct or indirect association with an individual;

XII – consent: free, informed and unequivocal manifestation by which the holder agrees to the processing of his or her personal data for a specific purpose;

XIII – blocking: temporary suspension of any processing operation, by keeping personal data or database;

XIV – elimination: exclusion of data or set of data stored in a database, regardless of the procedure employed;

XV – international data transfer: transfer of personal data to a foreign country or international organization of which the country is a member;

XVI – shared use of data: communication, dissemination, international transfer, interconnection of personal data or shared processing of personal databases by public bodies and entities in compliance with their legal competences, or between these and private entities, reciprocally, with specific authorization, for one or more processing modalities permitted by these public entities, or between private entities;

XVII – personal data protection impact report: documentation from the controller that contains a description of the personal data processing processes that may generate risks to civil liberties and fundamental rights, as well as measures, safeguards and risk mitigation mechanisms;

XVIII – research body: body or entity of the direct or indirect public administration or non-profit private legal entity legally constituted under Brazilian laws, with headquarters and jurisdiction in the country, which includes in its institutional mission or in its social or statutory objective basic or applied research of a historical, scientific nature, technological or statistical; and

XIX – national authority: public administration body responsible for ensuring, implementing and supervising compliance with this Law throughout the national territory”.

SECTION III – PERSONAL DATA COLLECTED AND PROCESSED

Our firm may collect personal data through forms on the website, emails, telephone calls and other means of communication. The data may include name, e-mail, ID, CPF, telephone, address, and other information necessary for the provision of our services.

Our website may use cookies to improve the user experience and/or for statistical analysis about its use. The user can set their browser to refuse the use of cookies, but this may impact the functionality of the website.

The information collected is used to: (a) serve customers and potential customers; (b) Sending communications about services and news; (c) Compliance with legal and regulatory obligations; and/or (d) Improve the user experience on the Website.

Personal data will be retained by the firm for the period necessary to fulfill the purpose for which they were collected, except in the event of compliance with legal, judicial and/or regulatory obligations.

SECTION IV – DATA SHARING

Personal data will not be sold or shared with third parties, except when necessary for compliance with legal obligations, for the execution of contracted services and/or for the regular exercise of our rights.

SECTION V – DATA STORAGE AND PROTECTION

We have adopted appropriate security measures to protect your information from unauthorized access, alteration, disclosure, improper destruction, or any form of improper treatment.

SECTION VI – THIRD-PARTY WEBSITES

Our firm’s website contains links to other sites on the Internet (e.g., Instagram, LinkedIn, IASP, Amazon, Editora Fórum, among others) to facilitate Users’ access to external content, such as publications, news, events, books, among others, but we are not responsible for verifying and/or validating the privacy policies of such websites. Thus, we recommend that users previously evaluate the privacy statements and policies of third-party websites so that they understand in advance how their personal data will be collected, used and stored through access to third-party platforms.

SECTION VII – RIGHTS OF THE PERSONAL DATA SUBJECT

The holder of the personal data has the right to obtain from our office, in relation to their data processed by our office, upon request, the following: (i) confirmation of the existence of processing of their data; (ii) access to your data; (iii) correction of incomplete, inaccurate or outdated data; (iv) anonymization, blocking, or deletion of unnecessary, excessive, or processed data in non-compliance with the LGPD; (v) portability of data to another service or product provider, in accordance with the relevant regulations, subject to commercial and industrial secrets; (vi) deletion of personal data processed with the consent of the data subject, except in the cases provided for in article 16 of the LGPD; (vii) information on possible data sharing with public and private entities; (viii) information about the possibility of not providing consent and about the consequences of refusal; (ix) revocation of consent, pursuant to paragraph 5 of article 8 of the LGPD; among other rights provided for in the LGPD.

SECTION VIII – COMMUNICATION CHANNELS

For requests dealing with the rights listed above and/or provided for in other applicable legislation, we provide the following contact email: contato@flobo.com.br

Before responding to any requests, our firm may adopt security measures to confirm the identity of the requester and/or to confirm that the request complies with applicable law.

SECTION IX – POSSIBLE CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We recommend checking in frequently to stay informed of any changes. Our website will make the current version available whenever it is updated.

São Paulo, April 1, 2025.

In charge, pursuant to article 5, VIII, of the LGPD, and Full Partner: Fernando Rissoli Lobo Filho, lawyer registered with the OAB/SP under No. 330.254 (original registration) and with the OAB/DF under No. 82.916 (supplementary registration).