1. OBJECTIVE
This Policy aims to establish Machado Meyer's guidelines for the processing of personal data within the scope of its activities, thus reiterating its commitment to respecting privacy and protecting personal data.
2. DATE OF EFFECTIVENESS
This Policy, which consolidates and replaces the privacy policies disclosed on 02/09/2021, becomes effective as of its disclosure, for an indefinite period, and may be revised and updated whenever necessary, in accordance with the responsibility matrix provided in the item 17 of this document.
3. TO WHOM IT APPLIES
This Policy applies to the data subjects of personal data processed by Machado Meyer:
- People who were or are Staff Members and their Dependents, Candidates, and Partners of Machado Meyer;
- All individuals linked to clients who have maintained or maintain a legal relationship with Machado Meyer;
- All individuals linked to suppliers who have maintained or maintain a commercial relationship with Machado Meyer;
- Visitors and registrants on our website, registered for Machado Meyer events, and to Third Parties visiting our Offices.
4. GENERAL GUIDELINES
4.1 The Policy is published and disclosed internally on our intranet and externally on the website www.machadomeyer.com.br/en and available for reading, according to the following wording.
4.2 We explain in the Policy, in a clear and transparent way, for the holders, what is done with the personal data processed by Machado Meyer.
4.3 The following topics clarify for what purposes the holders' personal data are used, for how long, how it is possible to access them, update them and obtain additional information.
5. WHAT PERSONAL DATA DO WE COLLECT / STORE / PROCESS?
The details of the personal data that can be collected, stored and processed by Machado Meyer are as follows:
5.1 People who were or are Staff Members and their Dependents, Candidates, and Partners of Machado Meyer
- Registration data: name, initials, corporate e-mail, RG, CPF, marital status, date of birth, telephone, address, profession, education, professional registration, signature, contact person, identification of the Staff Member and relative, position held, agency where he/she works, and period of employment, degree of kinship between PEP and Staff Member, employment record booklet, PIS, voter ID, reserve member certificate, education, gender, registration, description of activities performed at the client (timesheet), termination date, hiring date, and changes in position, OAB, cost center, academic certificates, Dependents (name, date of birth, birth certificates, marriage, or stable union), overtime, age of spouse and children, passport, projects carried out, name of manager, CNH, publications (books, articles, newspapers, magazines), photo, CCTV image, videos;
- Financial data: salary, consigned loan, FGTS statement, Partners' credit card;
- Sensitive data: digital biometrics, blood type, occupational health certificates (ASO's upon hiring, periodic, return to work, and upon dismissal), disability certificate, medical certificate, physical disability, racial origin, labor union membership);
- Behavioral data (work experience, competency assessment).
5.2 All individuals linked to clients who have maintained or maintain a legal relationship with Machado Meyer
- Registration data: name, RG, CPF, CNH, PIS, CTPS, passport, voter ID, education, e-mail, business address, home address, landline, mobile phone, language, position, company, profession, gender, date of birth, nationality, marital status, signature, photos, videos, CCTV image;
- Financial data: salary, as applicable in the context of the services provided to you; and
- Sensitive data: union membership, physical disability, medical certificates, medical reports, occupational health certificates - ASO, occupational accident reports - CAT, and other data that may be provided under the contractual relationship established between the Client and Machado Meyer, in the context of the provision of legal services.
5.3 All individuals linked to suppliers who have maintained or maintain a commercial relationship with Machado Meyer
- Registration data: name, RG, CPF, CNH, PIS, INSS registration number, e-mail, business address, home address, landline, mobile phone, department, position, company, profession, date of birth, nationality, marital status, professional registration (e.g. OAB, CRC), signature, photos, videos, CCTV image;
- Financial data: bank details, salary;
- Sensitive data: racial origin, biometrics (only in units of São Paulo and the Federal District).
5.4 Visitors and registrants on our website, registered for Machado Meyer events, and to Third Parties visiting our Offices
- Registration data: name, RG, CPF, nationality, position, e-mail, phone, mobile number, company, area of interest, date of birth, gender, contact person, CCTV image;
- Behavioral data: pages from the Website accessed, origin of access - e.g. google search, according to Annex 1 - Cookies.
5.5 Machado Meyer requires specific consent from a parent or legal guardian to perform treatments involving personal data of children or adolescents.
5.6 Machado Meyer only Machado Meyer requires specific consent from a parent or legal guardian to perform treatments involving personal data of children or adolescents processes sensitive personal data supported by legal basis, such as the explicit consent of the data subject or to comply with a legal obligation.
6. WHO IS RESPONSIBLE FOR THE DATA COLLECTED?
6.1 Machado Meyer, when in the condition of controlling agent, will make decisions regarding the personal data processed within the scope of the relationship established with you.
6.2 Machado Meyer, when in the condition of operating agent, will process the personal data received from the contracting party to fulfill the obligations established by it in the contract and use personal data strictly necessary and adequate to achieve the proposed purpose.
7. FOR WHAT PURPOSES IS PERSONAL DATA PROCESSED?
There are several purposes for which personal data are processed by Machado Meyer, detailed below:
7.1 People who were or are Staff Members and their Dependents, Candidates, and Partners of Machado Meyer
- Hiring people: recruitment, selection, hiring, dismissal, granting of benefits for employees and their dependants, people management, professional development, corporate education, internal communications, and contractual obligations;
- Identification of PEP - Politically Exposed Persons, including spouses/partners, stepchildren, relatives in a direct line up to second degree, for accreditation of the firm to provide services to clients, and compliance with specific legislation;
- Publication of relevant cases in legal directories that offer legal research and analysis and highlight the best law firms and professionals;
- Management of costs and expenses;
- Coordination of projects and work demands;
- Security and physical access control for Staff Members and third parties to the firm’s premises;
- Registration of Partners for the use of banking services;
- Maintaining custody of documents to support legal, tax, and business requirements;
- Records of the activities performed for the calculation of fees;
- Strengthening of brand value through external communication and sponsored events;
- Compliance with a legal or regulatory requirement (e-Social, DIRF, and D-SUP - Municipalities);
- Information security and business continuity plan.
7.2 All individuals linked to clients who have maintained or maintain a legal relationship with Machado Meyer
- Rendering of the services hired by the Client to defend its interests in judicial and extrajudicial proceedings;
- Use of specialized services to manage the proceedings;
- Maintaining custody of documents to support legal, tax, and business requirements;
- Records of the activities performed for the collection of fees;
- Registration of Clients and their respective contacts for use in the correct and timely issuance of invoices;
- Client Prospecting through research of contacts via internet and social networks;
- Security and physical access control to office premises;
- Security and physical access control to the office premises;
- Promote brand value and engage with new contacts and potential clients through sponsored events;
- Publication of relevant cases in legal directories that offer legal research and analysis, preserving Client confidentiality as appropriate;
- Comply with a legal or regulatory requirement.
7.3 All individuals linked to suppliers who have maintained or maintain a commercial relationship with Machado Meyer
- Hiring professionals for specialized services in judicial and extrajudicial proceedings and outsourced services (reception, cleaning, maintenance);
- Supplier management: assessment, homologation, registration, contract drafting e payments;
- Maintaining custody of documents to support legal, tax, and business requirements;
- Security and physical access control to the office premises;
- Information security and business continuity plan;
- Control of internal and external mail (Dispatch);
- Internal and external publicization (social networks) of training/events sponsored internally by Machado Meyer;
- Compliance with a legal or regulatory requirement.
7.4 Visitors and registrants on our website, registered for Machado Meyer events, and to Third Parties visiting our Offices
- Prospect clients through research of contacts via internet and social networks;
- Maintain the Security and physical access control to the office premises;
- Promote brand value and engage with new contacts and potential clients through sponsored events;
- Enable online registration for events promoted by Machado Meyer;
- Possibility of online registration to events promoted by Machado Meyer;
- Offer legal services of interest to Users;
- Carry out relationship campaigns with potential clients.
8. WITH WHOM MAY PERSONAL DATA BE SHARED?
8.1 People who were or are Staff Members and their Dependents, Candidates, and Partners of Machado Meyer
Machado Meyer may share your personal data with:
- Companies that provides benefits to partners, employees, and their dependents, such as health insurance, life insurance, private pension plan, transportation vouchers, meal vouchers, and fitness centers;
- Clients for the accreditation process carried out when hiring services;
- Independent research and legal analysis companies for publication of relevant Machado Meyer cases in legal directories;
- Financial institutions for the use of banking services;
- Educational institutions and suppliers for professional development and corporate education;
- Partner firms abroad for the selection process;
- Competent public authorities (judicial and extrajudicial), government entities, regulatory or tax agencies for which Machado Meyer is subject to comply with a legal or regulatory obligation or under applicable local law;
- Operating agents who handle your personal data in accordance with Machado Meyer's instructions:
- Technology service providers;
- Brand promotion companies, agencies organizing events promoted by Machado Meyer;
- Providers of specialized services for internal and external communications, such as translation of curriculum vitae, photography, and filming;
- Providers related to physical security whenever you access our office premises.
8.2 All individuals linked to clients who have maintained or maintain a legal relationship with Machado Meyer
Machado Meyer may share your personal data with:
- Independent research and legal analysis companies for publication of relevant Machado Meyer cases in legal directories, ensuring the maintenance of professional secrecy in relation to the Client;
- Competent public authorities (judicial and extrajudicial), government entities, regulatory or tax agencies for which Machado Meyer is subject to comply with a legal or regulatory obligation or under applicable local law;
- Operating agents who handle your Personal Data in accordance with Machado Meyer's instructions:
- Specialized service providers for the execution of the hiring and provision of services focused on you;
- Technology service providers;
- Event organizing agencies to offer the services you have requested or that may be of interest to you;
- Document safekeeping services companies;
- Providers related to physical security whenever you access our office premises.
8.3 All individuals linked to suppliers who have maintained or maintain a commercial relationship with Machado Meyer
Machado Meyer may share your personal data with:
- Client companies when requested;
- Competent public authorities (judicial and extrajudicial), government entities, regulatory or tax agencies for which Machado Meyer is subject to comply with a legal or regulatory obligation or under applicable local law;
- Operating Agents who handle your personal Data in accordance with Machado Meyer's instructions:
- Authorized service providers to support supplier management and for the execution of Machado Meyer’s professional activity;
- Technology service providers;
- Document safekeeping services companies;
- Providers related to physical security whenever you access our office premises.
8.4 Visitors and registrants on our website, registered for Machado Meyer events, and to Third Parties visiting our Offices
Machado Meyer may share your personal data with:
- Operating Agents who handle your personal Data in accordance with Machado Meyer's instructions:
- Technology service providers;
- Event organizing agencies to provide services requested by you or that may be of interest to you; and
- Providers related to physical security whenever you access our office premises.
9. IS PERSONAL DATA TRANSFERRED?
Machado Meyer uses cloud systems, for this reason it is possible that Personal Data may be transferred outside Brazil (currently, to Chile and the United States of America- USA), since they are the backup countries for the data storage of our service provider. To ensure that your Personal Data is processed solely for the stated purposes, we will adopt safeguards and guarantees such as specific clauses, standard clauses, and global corporate standards.
10. FOR HOW LONG IS PERSONAL DATA KEPT?
The Personal Data collected and processed by Machado Meyer shall be stored until the purpose of the Processing is exhausted or when there is no longer a legitimate purpose or a legal and regulatory reason that allows Machado Meyer to retain it.
11. HOW WILL WE KEEP THE DATA WE PROCESS IN OUR CUSTODY SECURE?
11.1 We adopt safety standards set forth in applicable laws and regulations, such as:
- Training, governance, internal security policies;
- Control of storage on internal or outside servers;
- Software to encrypt data collected;
- Protection against unauthorized access;
- Authorized access only to specific persons to the place where your personal information is stored, provided that such access is essential for the performance of the intended activity;
- Confidentiality of the professionals who access the information/data;
- Application of administrative, disciplinary, and legal sanctions Against Staff Members and persons who unduly use your information, in violation of this Privacy and Information Security Policy;
- Absolute commitment to the principles laid down by the applicable laws and regulations, as well as the storage and deletion of data, the latter when requested;
- Access by Data Subjects to all of their information stored.
11.2 While our best efforts are put into preserving your privacy and protecting your personal Data, it is important for you to know that no transmission of information is ever completely secure. For this reason, Machado Meyer cannot fully guarantee that all the information it receives and/or sends will not be subject to unauthorized access and performed through methods designed to obtain information improperly, such as viruses or database intrusions.
11.3 In the event of a breach of Personal Data in our custody, we guarantee we will make every effort to remedy the consequences of the event.
12. WHAT ARE MY RIGHTS?
12.1 In order to ensure your privacy and the protection of your data, Machado Meyer will facilitate the exercise of the rights described in article 18 of Law 13,709/2018, General Personal Data Protection Law, as applicable, which are:
- confirm the existence of Processing;
- access the data;
- correct incomplete, inaccurate, or outdated data;
- request anonymization, blocking, or elimination of unnecessary or excessive data or data processed in violation of the provisions of the General Personal Data Protection Law;
- request portability of data to another provider of a service or product, upon express request, in accordance with the regulations of the national authority, subject to commercial and industrial secrets;
- request erasure of personal data processed with the consent of the Data Subject, except in the cases provided for in article 16 of the General Personal Data Protection Law;
- obtain information on public and private entities with which the Controller has shared the use of data.
12.2 To meet the above requests, we will undertake all reasonable efforts within the shortest time possible, but you should be aware that the following may occur:
- Possible delay in service due to justifiable factors, such as the complexity of the request.
- Rejection of your request for formal (e.g., if you are unable to prove your identity) or legal reasons (e.g., request for deletion of data that may be kept by force of law or regulation; request for copy of a document that will only be provided if there is explicit consent; request for portability due to lack of specific regulation for the activity performed by Machado Meyer).
12.3 For any case of impossibility of meeting your request, Machado Meyer will provide due reasons.
13. HOW CAN I EXERCISE MY RIGHTS?
You can exercise the rights mentioned in the previous topic through the privacy form by clicking here.
14. HOW CAN I GET MORE INFORMATION?
14.1 In the policy, all the relevant and necessary information regarding the Processing of your personal Data may be found and, therefore, we strongly recommend reading it in full.
14.2 Should any questions remain after reading this policy in its entirety, you may contact our Data Protection Officer (DPO) at the following e-mail address click This email address is being protected from spambots. You need JavaScript enabled to view it..
15. DEFINITIONS
TERM | DEFINITION |
Website user | Individual who accesses and registers on Machado Meyer's website. |
Third Party | Individual who visits the Website and the premises of Machado Meyer, or a person who signs up for events available on the Website. |
Personal data | Any information related to a directly or indirectly identified or identifiable individual. |
Sensitive personal data | Special category of personal data concerning racial or ethnic origin, religious belief, political opinion, membership in a trade union or a religious, philosophical, or political organization, concerning health or sex life, genetic or biometric data concerning individuals. |
Data subject | Individual to whom the personal Data refers, such as, for example, the persons to whom this policy applies: people who were or are Staff Members and their Dependents, Candidates, and Partners of Machado Meyer; all individuals linked to clients who have maintained or maintain a legal relationship with Machado Meyer; all individuals linked to suppliers who have maintained or maintain a commercial relationship with Machado Meyer and visitors and registrants on our website, registered for Machado Meyer events, and to Third Parties visiting our Offices. |
Data Protection Officer (DPO) | Person appointed by the Controller and Operator to act as a communication channel between the Controller, the data Holders, and the National Data Protection Authority (ANPD). |
Website | Designates the electronic address www.machadomeyer.com.br and its subdomains. |
Processing | Any operation performed with personal Data, such as those relating to the: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, discarding, assessment, or control of the information, modification, dissemination, transfer, diffusion, or extraction. |
Controller | An individual or legal entity, governed by public or private law, who is responsible for decisions concerning the processing of personal data. |
Operator | Individual or legal entity, whether governed by public or private law, who carries out the Processing of personal Data on behalf of the Controller. |