PRIVACY POLICY | ABordin

This Privacy Policy (“Privacy Policy”) governs the collection, use and storage of data collected by means of the business developed by ASSESSOR-BORDIN CONSULTORES EMPRESARIAIS LTDA., duly enrolled with the Corporate Taxpayers’ Register (CNPJ/MF) under No. 52.190.527/0001-20, with principal place of business at Avenida Pedroso de Morais, 433, 5º ao 8º e 13º andar, Pinheiros, in the City of São Paulo, State of São Paulo, Zip Code (CEP) 05419-000 and with branch duly enrolled with CNPJ/MF under No. 52.190.527/0003-91, at Alameda Rio Negro, 500, Torre 2, 1º andar, conj. 115 e 116, Alphaville Centro Industrial e Empresarial, in the City of Barueri, State of São Paulo, Zip Code (CEP) 06454-000 (“ABORDIN”)

PLEASE READ CAREFULLY: When using the services provided by ABORDIN, the Personal Data Subject (Subject) represents to understand the terms hereof, and to fully agree with such terms. Subject furthermore understands that ABORDIN provides outsourcing, consulting, audit, forensic accounting evidence, and drafting of income tax return services.

As a general rule, ABORDIN may be classified as a processor in what concerns the processing of its clients’ personal data. In certain events, it is classified as a controller, especially when making decisions as to which data collect and how to process such data.

1 – PERSONAL DATA COLLECTED:

ABORDIN may collect personal data and information, including sensitive personal data, in order to allow for the accurate and appropriate provision of its Services, in compliance with and performance of legal and contractual obligations. Such personal data includes: name, identity card (RG), Individual Tax Identification Number (CPF), private telephone number, personal e-mail, business address, business telephone number, corporate e-mail, title, bank account and payment data, profile information in social media, pictures, images, videos, phonographic data, criminal records, bank statements, Income Tax return information, accounting, tax, corporate, and managerial documents.

ABORDIN may use all legal means to confirm the truth of the Personal Data, though it accepts no liability whatsoever, in any event, for any inaccurate or untrue data informed by Subject. As such, Subject warrants and undertakes liability for the truth, accuracy, and authenticity of all data provided to ABORDIN.

ANY DATA PROVIDED BY SUBJECT TO ABORDIN IS AN ACT OF FREE AND UNDISPUTABLE EXPRESSION OF WILL, WHEREBY SUBJECT EXPRESSLY CONSENTS TO THE PROCESSING OF SUCH DATA, AND ACKNOWLEDGES AND UNDERSTANDS THAT THE UNAVAILABILITY OF ANY REQUESTED DATA MAY AFFECT THE QUALITY OF THE SERVICES PROVIDED.

In any event, ABORDIN agrees to only collect the personal data necessary to provide each Service; in other words, it always seeks to minimize the collection of personal data.

The personal data provided to ABORDIN shall remain confidential and shall only be disclosed as is necessary and indispensible for the provision of the Services, performance of any legal or procedural obligation, or according to Subject’s consent. When necessary, such data shall be anonymized.

The Services provided by ABORDIN are dynamic and may result in the collection of other data and information. Subjects shall be notified should there be any change to the use thereof, and shall have a ten-day period to remove such consent, pursuant to the terms described in this Privacy Policy.

2 – DATA COLLECTION PURPOSES:

The Subjects’ Personal Data shall be used for the following purposes:

To provide, manage, expand, improve ABORDIN’s Services;
To perform contractual obligations;
To perform any legal and tax obligations and court orders that may apply. Such obligation shall continue to exist even upon termination of the contractual relationship, if necessary;
To adequately meet the Subjects doubts and requests;
To inform the Subjects on any news, functionalities, tools, contents, novelties, and other relevant events to maintain the relationship with the Subjects;
To promote client testimonies;
To send key alerts and notices with respect, for instance, to the conditions and Use and Privacy Policies;
To cooperate with and/or meet requirements made by government authorities; and
To share data collected with ABORDIN’s partners.

ABORDIN may establish partnerships with independent third parties to optimize Subject’s experience, including, but not limited to internet search tools and product or service providers (“Partners”). In said event, strictly in compliance with the agreement and the Subjects’ anonymity, any data provided by Subject to ABORDIN may be shared with the Partners, who must comply with the Privacy Policy implemented by ABORDIN. SUBJECT HEREBY AGREES TO SHARE DATA WHEN NECESSARY TO OBTAIN ANY BENEFITS.

3 – NOTIFICATIONS TO THE SUBJECTS:

When using our Services, Subject authorizes ABORDIN to make calls, send WhatsApp messages, e-mails, or any other instant messaging application for such purposes, and/or SMS, push notifications and/or app notifications, with informative and promotional content strictly related to the Services. Should Subject wish to revoke the consent granted, Subject must send an opt-out including Subject’s full name and telephone number to e-mail contato@corpsevices.com.br

Any notices served by e-mail are important for the interaction with Subject and are inherent to the provision of the ABORDIN Services.

4 – USE OF COOKIES AND OTHER TECHNOLOGIES:

The ABORDIN website uses cookies or other identification technologies to help customize the Subject’s experience. Cookies are small text files stored in the computer’s memory. A cookie contains information, personal information included, that may be read in the future by a server located in the domain that issued it. The information and data the cookies collect include the date and time of the Subject’s visit, browsing history, etc.

Cookies bring several benefits, as they allow for the identification of old Subjects when they return to the Platform, whereby such Subjects may be directed to personalized content and/or similar services. Cookies also save time, making it unnecessary to enter the same information and data over and over again.

Subject may disable such technologies at any time, by changing the settings of one’s browser or device. However, it is important to note that some features of the Platform may not work properly due to this configuration.

5 – PERSONAL DATA SECURITY AND SENSITIVE PERSONAL DATA:

The safety of all data shared by Subject is very important for ABORDIN, which takes the necessary measures to protect the data collected against loss, theft, or other improper use modalities and unauthorized access, but without any guarantee of infallibility, whereby ABORDIN is exempted from any liabilities for any losses and/or damages arising out of failures, viruses or invasions to the database, except in the event in which the exclusive fault thereof is proven.

ABORDIN follows the following security standards, as recommended by the competent authorities, to protect the collected data:

a) Use of standard and market methods to encrypt and anonymize the collected data, as well as standard forms of encryption to ensure the inviolability thereof;

b) Use of high-tech software to protect against unauthorized access to systems, which are deemed a controlled and safe environment;

c) Access to the places where the information is stored is only granted to previously authorized persons, who are committed to keeping such information in absolute secrecy, which, if not observed, shall result in civil liability and the consequences of court measures, in the form of Brazilian legislation;

d) Use of authentication mechanisms to access records capable of individualizing the person responsible for handling the records, as determined by Article 13 of Decree 8,771/2016 and Law 13,709/2018; and

e) Preparation of the inventory containing the time, duration, identity of the employee or person responsible for access, designated by the company and the file accessed, based on connection and application access records, pursuant to the terms of Article 13 of Decree 8,771/2016, in Law 13,709/2018.

6 – DATA SHARING AND DISCLOSURE: ABORDIN shall deem all information collected on the Subject as confidential.

Subject hereby agrees to share one’s data, pursuant to the terms of Article 7, Paragraph Five of Law 13,709/2018, for the purposes set out herein, and with third parties, in the following events:

a) With the companies that partner with ABORDIN and the subsidiaries thereof, to allow for the appropriate provision of the Services;

b) In the event of corporate transactions, changes and amendments related to ABORDIN, whenever the transfer of the information is key for the continuity of the Services; or

c) Upon court order or upon request of the administrative authorities, which hold legal authority and jurisdiction for such requirement.

The use of, access to and sharing of the data collected by ABORDIN shall be made within the limits and according to the purposes of the Services provided, and may be made available for consultation and assigned to ABORDIN’s business partners, suppliers, and authorities, provided if in compliance with the terms set out herein.

7 – INTERNATIONAL DATA TRANSFER:

ABORDIN is headquartered in Brazil and the data collected thereby is governed by Brazilian laws.

ABORDIN transfers the data collected in Brazil to servers located in the USA, Israel, and Switzerland. Such transfer occurs to ABORDIN’s partners operating in data processing, and involves companies that prove to be in the process of compliance or in compliance with the applicable data protection laws.

Upon access to or use of ABORDIN’s services, or upon provision of personal data, User agrees to the processing and transfer of such data to Brazil and to the USA, Israel and Switzerland. When transferred to the USA, Israel and Switzerland, such data may be subject to local laws and applicable rules.

8 – ACCESS TO DATA:

ABORDIN warrants that it uses the limited access policy; in other words, Subjects’ personal data and information are limited to those whose purpose requires contact with the personal data, and for the purposes and within the limits hereof.

9 – SUSPECTED DATA VIOLATION:

In the event of suspected data violation, ABORDIN shall notify Subjects that may be have been affected and shall trace all activities performed during the last period, since the latest suspicion.

10 – RIGHTS OF THE DATA SUBJECTS:

The Subject may exercise the rights to Access, Correction, Cancellation, and Opt-ut. Only the identifiable data are subject to the exercise of such rights. Subject’s rights include:

Right to access: allows the Subject to know and obtain information about the personal data subject to processing;
Right to collect and delete: allows for errors to be corrected and for inaccurate and incomplete data to be modified;
Right to cancel: allows for inappropriate or excessive data to be deleted;
Right to opt out: Subject's right to prevent the processing of their personal data or to cease the ongoing processing;
Right to restrict processing: involves marking stored personal data to restrict further processing thereof;
Data portability: provision of Subject data that is subject to processing so that it may be transferred to another controller, without any impediments; and
Right to withdraw consent given at any time, pursuant to Article 18 of Law 13,709/2018, and the Subject may request that their data be deleted, regardless of the consent given at any given time.

Subject is hereby aware that ABORDIN may maintain the processing of certain personal data for the purposes described in Article 16 of Law 13,709/2018, especially for the performance of legal or regulatory obligation.

ABORDIN reserves itself the right to use all legal means necessary to determine the identity of those who request to exercise the rights described above, in order to prove they are the relevant data Subjects.

11 – REVOCATION OF CONSENT:

ABORDIN shall make its best efforts to reply to all lawful requests for revocation of consent within fifteen (15) days. It may occasionally take up to thirty (30) business days, should the request be particularly complex, or if Subject has made several requests. Should it take longer than expected, Subject shall be notified.

12 – PERSONAL DATA RETAINED:

ABORDIN shall retain the Subject’s personal data only for the time that may be necessary to comply with the purposes for which it is collected and processed, including for the purposes of performing legal, contractual or accounting information, or to meet requirements made by the competent authorities.

In order to determine the appropriate retention period of the personal data, ABORDIN takes into account the number, nature and sensitivity of personal data, potential risk of security accidents that may occur, and the purpose of the personal data processing.

13 – AMENDMENTS TO THE PRIVACY POLICY:

ABORDIN reserves itself the right to amend the Privacy Policy, as well as any other policy of the Platform, at any time and at its sole discretion. The amendments shall become effective upon relevant publication in the Platform. The use thereof after the publication shall constitute acceptance of any amendments to the Privacy Policy. If Subject does not agree with the updated terms of the Privacy Policy, then the use of the Platform shall be discontinued.

In the event of substantial amendments hereto or to how ABORDIN uses the Subjects’ information, ABORDIN shall make reasonable efforts to inform and render such amendments public, for instance, by means of a notice at the Website. The continued use of the tool after such amendments shall be deemed acceptance of the changes made.

14 – QUESTIONS AND FURTHER CLARIFICATION:

Subject may contact ABORDIN, including to seek clarification on the Privacy Policy, by e-mail: contato@corpservices.com.br

Subject represents to have read, understood and accepted all the rules, conditions and obligations set forth in this Privacy Policy.

Last updated on April 13, 2022.

Politica de Privacidade