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  • Writer's pictureHugo Crema

Privacy Policy

HCM Tradução Jurídica is committed to the security of your personal data. We take reasonable precautions to maintain this security. HCM employs security systems and technical, physical, and managerial procedures adopted in the market to protect your information from unauthorized access and accidental or illicit situations of destruction, loss, alteration, communication or any form of inadequate or illicit treatment.


We recommend you read this policy carefully. It describes how the personal data provided, which allow the platform functionality, are treated.


Objectives of this Policy

It is our policy to respect your privacy related to the treatment of your Personal Data or Sensitive Personal Data. With the commitment to privacy and transparency, HCM Tradução Jurídica has created this Privacy Policy ("Privacy Policy") to provide you with a clear understanding of how we treat your personal data under the General Data Protection Law.

HCM Tradução Jurídica will, for the most part, be the Controller of your personal data within the scope of the relationship established with you. For the purposes of the applicable legislation, the Controller is the person who is responsible for decisions regarding the processing of personal data.

What Data Can Be Handled by HCM?

HCM only requests personal information when strictly necessary for the provision and performance of our legal services. The data is requested in the best and safest way possible. Thus, to the extent permitted by law, we may process the following data:

  • Identification and contact data: full name; address; date of birth; nationality; identification document(s) data (RG, CPF, CNH or OAB, as applicable), e-mail address, telephone number

  • Corporate data: CNPJ, State and Municipal Registration, Corporate name, corporate board, corporate email addresses, phone numbers

  • Academic and professional data: employer; profession; position; education, among others.

In the provision of translation services, considering the support to clients in the most diverse areas and specialties, HCM Tradução Jurídica may have access and treat a large set of personal data or even third parties' personal data, depending on the object or reason of the documents in question. Some examples of personal data that HCM may treat in the rendering of its services are:

  • Registration information: name, CPF, RG, address and telephone number;

  • Financial information: remuneration; transaction history; credits; sales; possessions; debt certificates; loans;

  • Family information: family structure and relationships;

  • Information contained in processes: date of birth; nationality; place of birth; age; marital status; country; address; CNH; electoral title; military conscription; profession; education; languages; professional registration; PIS/PASEP; CTPS; NIS; NIT; CEI.

This personal data is treated only from the point of view of document translation, when necessary for the provision of services and to achieve the purposes mentioned in this Privacy Policy.


And why do we process your data?


In general, personal data is processed solely and exclusively for customer service and the provision of translation and consulting services, but is not limited to:

  • Client registration;

  • Translations, revisions, versions, interpretations, and textual quality control

  • Training;

  • Conducting meetings, videoconferences, or conference calls to discuss general topics

  • Obtaining necessary licenses, authorizations, and permits;

  • Preparing, reviewing or negotiating contracts;

  • Pro bono work;

  • Intermediation of the client's relationship with authorities and government agencies;

  • Preparation of documents required under Brazilian law;

We may also process your personal data for purposes of formalizing the contract with HCM, billing, and collection if you are the client (natural person) or a client's representative (legal entity). In addition, we may process your personal data to maintain our relationship with you in the following instances:

  • Sending institutional communications, memos or newsletters with topics of your interest and invitations to events;

  • Organizing events, including managing registrations, sending save the date, reminders, and thank you notes. To guarantee your easier access and comfort in the event, HCM Tradução Jurídica may ask if you have any disabilities or mobility restrictions;

  • Carrying out satisfaction and feedback surveys about our services and initiatives.


And who might HCM eventually share your data with?

From time to time, HCM may provide your personal information to national or international legal publications to allow them to contact you to evaluate and refer you to our services. In addition, as necessary, your personal data may be shared with:

  • Providers of software, cloud hosting services and other information technology for purposes of managing your relationship with HCM, registration, documentation and other arrangements;

  • Judicial, law enforcement, government authorities or other third parties with whom we are required by law, regulatory rule or court order to share data;

  • Non-governmental organizations in case of pro bono work;

  • National or international legal publications;

  • Business partners, such as event hosting and event organization companies; and

  • Regulatory agencies and other authorities, such as the Superintendence of Private Insurance (SUSEP), Ministry of Agriculture, Livestock and Supply (MAPA), and the National Telecommunications Agency (ANATEL).

HCM Tradução Jurídica clarifies that, as a rule, it does not share personal data with third parties, considering that HCM does not outsource translation activities. All activities related to the company's main activity are developed directly by its collaborators. The sharing of data with subcontractors only occurs with the client's prior consent and for the achievement of specific and previously agreed purposes.


How is your data handled?


Regarding its employees, on the occasion of the selection process, HCM opens the vacancy in a digital platform, where the candidate, through the database of this platform, sends his resume to the party interested in hiring. When the interview is held, and before the admission of the selected candidate, the HCM reanalyzes the CV. Soon, when hired, the collaborator is made aware of the compliance with the HCM data protection, having access to the company's policies and programs (privacy policy, compliance, confidentiality, among others).


In the hiring process, HCM Tradução Jurídica acts as a "Data Operator", while the Platform acts as a Controller, since the candidates' personal data are stored and treated in the latter's digital platform. HCM Tradução Jurídica in the condition of "Data Operator", values the duty to comply with good compliance and personal data protection practices, imposing awareness actions and technical actions aimed at cybersecurity.


The life cycle of your data that is collected, both in the selection process and throughout the relationship, includes policies from the capture, evaluation and access control to the ethical treatment, recovery, storage and destruction, being safeguarded the fulfillment of requests from titleholders and regulatory bodies.


During the relationship with the Data Operator, which is HCM Tradução Jurídica, your personal data are treated by software providers Google for Business, MateCat and Proton VPN, used by HCM.


How long can your data be stored?


We store and maintain your information for as long as required by law;

  • Until the end of the processing of personal data, as mentioned below;

  • For as long as necessary to safeguard the regular exercise of HCM's rights in administrative proceedings. Thus, we will process your data, for example, during the applicable statute of limitations or for as long as necessary to comply with a legal or regulatory obligation.

Termination of the processing of personal data will occur in the following cases:

  • When the purpose for which the Data Subject's personal data was collected is achieved and/or the personal data collected is no longer necessary or relevant to the achievement of such purpose;

  • When the Data Subject is in his or her right to request the termination of the processing and the deletion of his or her personal data and does so; and

  • When there is a legal determination to this effect. In such cases of termination of personal data processing, except in the cases established by applicable law or by this Privacy Policy, the personal data will be deleted.

We structure our operations so that your personal data is not kept in an identified manner longer than necessary. Thus, we keep personal data only for as long as it is necessary for the aforementioned purposes, if we are required to do so by law or for the regular exercise of our rights. We may keep your personal data in an anonymized form, i.e. without it being possible to identify the data subject, for longer periods.

Considering the eventual termination of the relationship between HCM and the Holder, we inform you that certain personal data and even sensitive personal data collected in the course of this relationship will be kept at our base for the fulfillment of legal or regulatory obligation, under the terms of art. 16, I of LGPD.


What can I, the data subject, do about the data?

You are the Holder of the personal data made available to HCM. In view of this, and based on what Law No. 13,709/18(LGPD) provides, the Holder will have the following rights ensured with regard to your data:

  • Confirmation that we carry out the processing of your Data;

  • Access to the Personal Data whose processing is carried out;

  • Possibility of performing the correction of incomplete, inaccurate or outdated data;

  • Possibility to request the anonymization, blocking or deletion of personal data;

  • Possibility to request the portability of your personal data to another service or product provider, subject to HCM's industrial and commercial secrets;

  • Deletion of personal data processed on the basis of consent, except in the event of hypotheses for the conservation of data provided by law;

  • Information about third parties with whom we share your Data;

  • Information about the possibility of not providing consent and the consequences of refusal;

  • Revocation of your consent, if we have requested this of you;

  • Opposition to processing that violates the LGPD and;

  • Right to petition the National Data Protection Agency (NPA).

In some circumstances, there is the possibility of restriction on the exercise of some rights provided by law, such as, for example, when the provision of information may reveal any HCM business secret or due to compliance with any legal/regulatory obligation or to allow the defense of HCM Tradução Jurídica in any judicial or administrative proceedings.


You may exercise the rights provided by law by contacting the Data Controller through the e-mail privacidade@hcmtraducaojuridica.com.br.

It is important to mention that the LGPD establishes several situations in which the processing of personal data is allowed regardless of the consent of the holder of that personal data. These are the so-called "legal grounds for data processing".

This means that in some cases we may collect and process your personal data regardless of your consent, provided there is a "legal basis" provided by law that allows us to do so. In other cases, we will ask for your consent to use your personal data.


Complaints or suggestions


In case of questions, criticism, suggestions, or complaints, you can contact the Data Officer through the e-mail privacidade@hcmtraducaojuridica.com.br, which will reply within a reasonable time, estimated, normally, at 10 (ten) days.


Consent


The use of HCM Tradução Jurídica website or the provision of personal data by any other means presupposes your agreement with this Privacy Policy. We reserve the right to modify this Privacy Policy totally or partially at any time, inserting the last update date as indicated below.


Policy changes


You should check this page periodically for changes. By continuing to use the platform and/or our services, you consent to this Privacy Policy as amended.

If there are changes to this Privacy Policy that are material in nature, we may require additional consent as a condition of your continued use of the platform and/or our services.


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