Privacy Policy

1. OBJECTIVE

1.1. To establish clear and transparent guidelines on the processing of personal data carried out by Salles Nogueira Advogados, especially through its institutional website, contact channels, and in the context of providing legal services, in compliance with the General Data Protection Law (LGPD - Law No. 13,709/2018), the Brazilian Civil Rights Framework for the Internet, and other applicable regulations.

2. SCOPE

2.1. This privacy policy (“Policy”) applies to the personal data processed by Salles Nogueira Advogados regarding website users, clients, potential clients, client representatives, suppliers, partners, correspondents, meeting or event participants, recipients of institutional communications, and other data subjects whose data may be processed in the context of the activities of Salles Nogueira Advogados.

3. DEFINITIONS, CONTROLLER, AND CONTACT CHANNEL

3.1. For the purposes of this Policy, the following definitions apply:

• Personal data: information related to an identified or identifiable natural person
• Sensitive personal data: data concerning racial or ethnic origin, religious conviction, political opinion, membership in a trade union or religious, philosophical, or political organization, data relating to health or sexual life, genetic or biometric data, when linked to a natural person
• Data subject: the natural person to whom the personal data being processed refers
• Processing: any operation performed with personal data, such as collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation, control, modification, communication, transfer, dissemination, or extraction
• Controller: the natural or legal person responsible for decisions regarding the processing of personal data
• Processor: the natural or legal person who processes personal data on behalf of the controller
• Consent: a free, informed, and unequivocal expression by which the data subject agrees to the processing of their personal data for a specific purpose
• Legal bases: authorizing hypotheses for the processing of personal data provided for in applicable legislation

3.2. The controller of the personal data processed under this Policy is Salles Nogueira Advogados. Requests, doubts, or requirements related to privacy and data protection may be sent via email to contato@sallesnogueira.com.br or through other official channels provided by Salles Nogueira Advogados.

4. COLLECTED PERSONAL DATA

4.1. Salles Nogueira Advogados may collect personal data provided directly by the subject, data generated automatically during website navigation, and data resulting from the professional or commercial relationship maintained with Salles Nogueira Advogados. The following may be processed:

• Registration and contact data, such as name, email, telephone, company, position, and city

• Data related to the request sent by the subject, such as the subject of the message, area of interest, content of the contact, and documents sent

• Navigation data, such as IP address, date and time of access, browser type, pages visited, device used, and records related to cookies and session identifiers

• Data necessary for formalizing contracts, billing, collection, fraud prevention, compliance with legal or regulatory obligations, and the provision of legal services themselves

4.2. Salles Nogueira Advogados does not deliberately request sensitive personal data through the institutional website, except when it is indispensable for the initial analysis or conduct of a specific legal demand and there is an adequate legal basis for the respective processing.

5. PURPOSES AND LEGAL BASES FOR PROCESSING

5.1. Personal data may be processed by Salles Nogueira Advogados for legitimate and specific purposes related to the operation of the website, institutional relationships, and the provision of legal services, including, without limitation:

• Responding to contacts, requests, doubts, and initial screening of demands
• Scheduling meetings, videoconferences, or telephone calls
• Drafting, reviewing, or negotiating contracts
• Conducting or participating in audits, compliance analyses, and risk assessments
• Management of investigations, inquiries, judicial, administrative, or arbitration proceedings
• Preparation of memorandums, legal opinions, responses to inquiries, and other legal documents
• Intermediation of the client's relationship with authorities, public bodies, and regulatory entities
• Obtaining licenses, authorizations, and necessary permits, assistance in bidding processes, and coordination of corporate, contractual, and capital market operations
• Formalization of contracts, billing, collection, and compliance with legal, regulatory, and ethical obligations
• Sending institutional communications, newsletters, memorandums, and informative materials
• Ensuring the security, operation, improvement, and integrity of the website and systems used by Salles Nogueira Advogados

5.2. The processing of personal data will be carried out based on applicable legal bases, depending on the specific case, including consent, preliminary procedures related to a contract, contractual execution, compliance with legal or regulatory obligations, regular exercise of rights, and legitimate interest.

6. SHARING OF PERSONAL DATA

6.1. Salles Nogueira Advogados may share personal data only when necessary to fulfill the purposes described in this Policy, always in compliance with applicable legislation and through the adoption of compatible contractual and security measures.

6.2. Salles Nogueira Advogados does not sell personal data collected in the exercise of its activities.

7. COOKIES AND SIMILAR TECHNOLOGIES

7.1. The Salles Nogueira Advogados website may use cookies and similar technologies to enable technical functionalities, maintain user preferences, enhance security, improve the browsing experience, and, when applicable, measure audience and performance.

7.2. Cookies are not used for undue user identification and can be managed or blocked directly in the browser settings. Blocking certain cookies, however, may limit website functionalities or prevent the proper operation of some features.

7.3. When the technology employed requires consent, it will be requested through appropriate mechanisms, in accordance with applicable legislation.

8. STORAGE, RETENTION, AND INTERNATIONAL TRANSFER

8.1. Personal data will be stored only for the period necessary to fulfill the purposes for which it was collected, for the execution of legal services, for compliance with legal, regulatory, or contractual requirements, and for the regular exercise of rights by Salles Nogueira Advogados.

8.2. Once processing is concluded and there is no legal basis for maintaining the data, it may be deleted, anonymized, or kept securely in the cases authorized by applicable legislation.

8.3. Salles Nogueira Advogados may use suppliers or technological solutions with servers located abroad, especially for hosting services, cloud storage, email, and technological support. In these cases, Salles Nogueira Advogados will seek to adopt appropriate measures to ensure a level of protection compatible with Brazilian legislation.

9. PROTECTION OF PERSONAL DATA

9.1. Technical, administrative, and organizational measures that are reasonable and compatible with the nature of the data processed will be adopted to protect it against unauthorized access, loss, destruction, alteration, disclosure, or any form of inappropriate or unlawful processing.

9.2. Although Salles Nogueira Advogados employs appropriate security efforts, no system is entirely immune to incidents. In the event of a relevant security incident, Salles Nogueira Advogados will seek to identify its cause, mitigate its effects, prevent recurrences, and adopt the necessary measures, including legally required notifications, when applicable.

10. DATA SUBJECT RIGHTS AND SERVICE CHANNEL

10.1. Under the terms of the LGPD and subject to legal and regulatory limits, the data subject may request from Salles Nogueira Advogados:

• Confirmation of the existence of processing
• Access to personal data
• Correction of incomplete, inaccurate, or outdated data
• Anonymization, blocking, or elimination of unnecessary, excessive data or data processed in non-compliance with the law
• Data portability, when applicable
• Information about sharing carried out
• Information about the possibility of not providing consent and the consequences of such refusal
• Revocation of consent, when this is the applicable legal basis

10.2. Requests may be sent to the email contato@sallesnogueira.com.br, with the identification of the data subject and details of the request. For the protection of the subject, Salles Nogueira Advogados may request additional reasonable information to confirm identity before fulfilling the request.

11. FINAL PROVISIONS

11.1. This Policy applies to the processing of personal data carried out by Salles Nogueira Advogados within the scope of its institutional website and contact channels, without prejudice to specific instruments applicable to certain relationships, operations, or services.

11.2. The website may contain links to external pages, including social networks, map platforms, messaging, or other digital services. Salles Nogueira Advogados is not responsible for the privacy practices of third parties, which is why it is recommended to consult the specific policies of each environment accessed.

11.3. The Salles Nogueira Advogados website is not intentionally directed at children. If, in an exceptional situation, personal data of children or adolescents is processed, it will occur in accordance with applicable legislation and with special regard to the best interest of the minor, when applicable.

11.4. This Policy may be altered at any time to reflect legislative, regulatory, technological, or operational changes. The current version will be the one published through the official means of Salles Nogueira Advogados.

11.5. This Policy comes into force on the date of its publication.