Privacy Policy

INTRODUCTION 

GJACINTHO CONSULTORIA CONTÁBIL E TRIBUTÁRIA S/S LTDA. (also referred to below as “we” or “our” or GJACINTHO) is a company that, since 1987, provides quality accounting and tax consultancy services and is committed with the protection of personal data and with clear and transparent data treatment.

In order to help you understand how we collect and use the personal data of individuals, customers, suppliers and others in our business, please read this Privacy Policy.

In case of doubt regarding this Privacy Policy, please contact the person in charge, Carolina Jacintho Rocha, through the following email address lgpd@gjacintho.com.br.

SUMMARY OF THIS PRIVACY POLICY

This Privacy Policy states which personal data GJACINTHO CONSULTORIA CONTÁBIL E TRIBUTÁRIA S/S LTDA., as well as other companies in the economic group, collects, what we use this personal data for, how and where we store it and with whom we share. It also establishes your rights regarding your personal data and who you should contact to obtain more information or clarification on this matter.

This Privacy Policy also states our commitment with the treatment of your personal data with responsibility, ethics, in line with our principles and values, and especially in accordance with the rules provided for in Law No. 13,709/2018 (General Data Protection Law – LGPD) and other applicable legislation in force.

WHEN AND WHICH PERSONAL DATA WE COLLECT OUR CUSTOMERS’ PERSONAL DATA

When you hire us to provide professional services, we collect and use personal data.

Most personal data we collect and use to provide our services is provided voluntarily by (or collected by us in third-party sources at the request of) our customers.

As a general rule, the data we collect on our customers include: basic information, like name, company where they work, age, date of birth, gender, ID registration number (RG), individual taxpayer enrollment number (CPF); telephone number, date of birth, social security number; INSS; national labor document, PIS/PASEP, marital status, other personal information before government agencies, contact information, like mailing address, email address and telephone number, financial information and any other personal data regarding themselves or third parties they might provide us for the purposes of receiving our services.

We use these data for:

• The provision of our services
• Managing our relationship and maintaining contractual relations
• Accounting and tax purposes
• For marketing and business development
• Fulfilling our legal and regulatory obligations
• Establishing, exercising and defending legal rights
• Historical and statistical purposes

The legal grounds for the processing of our customers’ personal data are:

• Execution of a contract
• Fulfillment of a legal or regulatory obligation
• Our legitimate interest in providing you with continuous, consistent and high quality services and ensuring immediate payment of any fees, costs or debts related to our services
• Our legitimate interest in understanding any conflict of interests or challenges with regards to legislation

PERSONAL DATA OF INDIVIDUALS IN CONNECTION WITH THE PROVISION OF SERVICES TO OUR CUSTOMERS

When providing services to customers, we can process the personal data of individuals who are not directly related to us (contractually or otherwise).

Customers ensure they have the authority to provide us with third-party personal data related to the provision of services.

Given the large diversity of services we provide, we process many categories of personal data, such as:

• Personal data (like name, age, birth details, gender, marital status and country)
• Contact details (such as telephone numbers, email address and mailing address)
• Financial details (such as salary, payroll, income, investment, benefits and fiscal status)
• Employment details (such as job, position, experience, performance data and employment numbers)
• For certain services, we also process other data

We use these data for:

• The provision of services to our customers
• Managing our relationship and maintaining contractual relations
• Accounting and tax purposes
• For marketing and business development
• Fulfilling our legal and regulatory obligations
• Establishing, exercising and defending legal rights

The legal grounds for the processing of individuals’ personal data whose personal data we have obtained in connection with services provided to our customers are:

• Execution of a contract
• Fulfillment of a legal or regulatory obligation
• Our legitimate interest to ensure that our customers receive continuous, consistent and high-quality services worldwide.

OUR SUPPLIERS’ PERSONAL DATA

We process personal data on our suppliers (including subcontractors and individuals associated with our suppliers and hired parties) in order to manage our relationship and contract, as well as receive services from our suppliers.

The personal data we process are usually limited to contact information (name, employer’s name, telephone number, email address and other contact details) and financial information (information regarding payment).

Furthermore, we also use data on our suppliers to check whether we have restrictions regarding conflict of interests or auditors’ independence to refer a supplier. Before we hire a new supplier, we also conduct independent audits and other background checks required by law or regulations.

The legal grounds for the processing of our suppliers’ personal data are:

• Execution of a contract
• Fulfillment of a legal or regulatory obligation
• Our legitimate interest in managing payments, fees and charges and collecting and recovering money due to GJACINTHO.
• Our legitimate interest in understanding any conflict of interests or challenges with regards to legislation

PERSONAL DATA IN RECRUITMENT AND SELECTION PROCESSES

We may collect information from and on candidates regarding job opportunities available at GJACINTHO.

As a general rule, the data we collect on our candidates for job opportunities include: resumes or CVs, ID documentation, academic records, employment history, employment information and references.

We use these data to: match their abilities, experience and education with specific positions offered by GJACINTHO, and this information is submitted to relevant hiring managers and the people involved in the recruitment process in order to decide if we should invite them for an interview.

The legal grounds for the processing of our job applicants’ personal data are:

• The applicant’s explicit consent
• Our legitimate interest in attracting, identifying and searching for talents.
• Our legitimate interest in processing and managing job applications at GJACINTHO, including the selection of candidates
• Our legitimate interest in hiring and incorporating applicants, making an offer to approved applicants and conducting pre-hiring checks

PERSONAL DATA OBTAINED THROUGH OUR WEBSITE, USE OF COOKIES, SURVEYS AND EVENTS AT GJACINTHO

We collect personal data you provide us voluntarily through our website, for example, when you fill out online forms to contact us, sign up to an informative newsletter, use one of our online reference tools, sign up to receive our marketing communication, take part in surveys or enroll in one of the events we are organizing.

The information we collect on you includes the following:

• First and Last Names
  Job title, level, job tasks, tasks
• Company or organization
  Company’s data
  Contact information, including main email, email address and telephone numbers
• Demographic information, such as industry, country, zip code, preferences and interests
• Other relevant information for customer surveys or similar
• Information regarding the fulfillment of our services
• Any other personal data you choose to voluntarily provide to us

We do not collect sensitive data intentionally unless you provide us with such data. Although there may be free text boxes in the website, where you can insert any information, we do not intend on processing confidential information. You are not required to provide, and should not disclose, sensitive personal information in our free text boxes. If you choose to provide any sensitive personal information this way, you agree with the collection and processing of this sensitive information.

Cookies:

When you visit our website, we collect certain personal data from your device automatically. Specifically, the data we collect automatically include information like gender, age, region and interest, and it is not possible to identify the user. We also collect information on how your device interacted with our website, including accessed pages and clicked links. The collection of this information allows us to better understand the profile of users who go into our website, where they come from and what content in our website interests them. We use this information for the purpose of internal analysis and to improve the quality and relevance of our website for our visitors. The information will be collected using cookies and similar tracking technology.

We also acquire cookies from third parties, that are classified as persistent and whose goal is publicity. Such cookies are used by websites like Google, Facebook and LinkedIn, which target adds from G.Jacintho and other companies to users according to each profile. It should be highlighted that these websites do not target any personal data from these users to G.Jacintho.

PERSONAL DATA FROM MINORS

We understand the importance of protecting the privacy and personal data of children and teenagers. Our website and our services are not designed for or intentionally target children and teenagers. It is not in our policy to intentionally collect and store information on this type of public, however, in certain situations where the collection and use of this type of personal data proves necessary, like, for example, the provision of services involving the analysis of personal data from dependents who are minors, the treatment shall be carried out in the child’s or teenager’s best interest, pursuant to current legislation.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data for the purposes described in this privacy policy or as stated during the data collection.

We can use your data for:

• Provision of services to you or our customer;
• Business development purposes;
• Meeting applicable legal and regulatory requirements;
• Managing and responding to any request you submit to us;
• Fulfilling request and communications from legal authorities;
• Opening customer accounts and other administrative purposes;
• Financial accounting, billing and risk analysis;
• Customer relationship purposes, which may include:
  • (i) sending detailed content on our products and services we believe may be in your interest;
  • (ii) contacting you to receive feedback on our services; and
  • (iii) contacting you for other market or survey purposes; and
• Protecting our rights and those of our customers.

TO WHOM WE DISCLOSE YOUR PERSONAL DATA

In connection with one or more of the purposes described in the section “How we use your personal data” below, we may disclose your details to:

• Other companies in GJACINTHO’s economic group, as well as their employees;
• Suppliers who support us and help us in providing services to our customers, like suppliers of cloud-based software, IT systems, accounting, financial control and tax payment, security, file storage, recruitment, marketing and payment services;
• Relevant legal authorities (including courts of law and regulating authorities or other members of GJACINTHO’s economic group);
• Technology companies responsible for storing and ensuring the security of the treatment of your data;
• Their employer and/or their advisors; their councilors; credit agencies;
• Or Other organizations that help us make decisions on credit and reduce the risk of frauds and other partners who reasonably demand access to personal data regarding you with one or more of the purposes described in the section “How we use your personal data” above.

INTERNATIONAL DATA TRANSFER

Please be advised that some of the recipients of your personal data may be located in other countries. In these cases, we ensure you that we will adopt all possible provisions to protect your personal data in accordance with our legal obligations. When the recipient is not a member of GJACINTHO’s economic group, the adequate insurance may be a data transfer agreement with the recipient, based on standard contractual clauses approved by the National Data Protection Authority, or other relevant authority for the transfer of personal data to other countries.

HOW WE PROTECT YOUR PERSONAL DATA

We use a series of physical, electronic and management measures to ensure that your personal data is safe, precise and up-to-date.

These measures include:

• Education and training of the responsible team, so they are aware of our privacy and data protection obligations when handling personal data;
• Administrative and technical controls to restrict access to personal data, in accordance with the need to know;
• Technological security measures, including firewalls, encryption and antivirus software; and
• Physical security measures, such as security passes for employees to access our facilities.

Although we use appropriate measures, since we receive personal data, the transmission of data through the internet (including via email) is never completely secure. We strive to protect your personal data, but cannot ensure the security of the data transmitted by us or to us.

Aiming to duly protect and treat your personal data in compliance with the General Data Protection Law, besides other applicable legislation, we undertake to:

• Adopt security, technical and administrative measures so as to protect unauthorized access personal data and from accidental or illegal cases of destruction, loss, alteration, communication, unauthorized access or other forms of inadequate or illegal treatment;
• Upkeep the registration of personal data treatment operations conducted, especially when based on legitimate interest;
• Communicate, within a reasonable period of time, to the National Data Protection Authority and the holder of the security incident that may lead to risk or relevant damages to holders;
• Use systems for personal data treatment that are structured so as to meet security requirements, good practices and governance standards and general principles provided for in the General Data Protection Law;
• Discard personal data after the end of treatment, within the scope and technical limits of the activities, with the proviso that conservation of data is permitted for the purposes provided for in legislation; and
  Comply with guidelines, rules and regulations issued by the National Data Protection Authority.

FOR HOW LONG DO WE KEEP YOUR INFORMATION

We keep your personal data in our system during the largest of the following periods:

• While it is necessary for the provision of services;
  any retention period required by law;
• End of period in which the litigation or investigation regarding the services may arise;
  while its consent is valid, in the applicable hypotheses;
• Pursuant to current legislation.

KNOW YOUR RIGHTS

You have many rights regarding your personal data, which may be exercised at any time, free of cost, via a request registered before our Responsible Person.

Based on the General Data Protection Law, you have the right to:

• Obtain confirmation that we are treating your personal data and request a copy of the personal data we keep on you;
• Request that we update the personal data we keep on you or that we correct the data you think is incomplete or incorrect;
• Withdraw the consent granted for the processing of your personal data, as well as request its removal (if such processing is based on the consent);
• Request portability on the personal data we store on you to other product or service provider, provided trade and industrial secrets are complied with, as well as applicable confidentiality;
• Obtain information on who we jointly use your data with;
• Request that your personal data that you perceive as unnecessary, excessive or treated not in compliance with the General Data Protection Law are anonymized, blocked or discarded;
• Request review of decisions made solely based on automatized treatment of personal data.

PERSON RESPONSIBLE FOR DATA

If you have any doubts on our privacy policy, feel dissatisfied with the use we make of personal data or wish to exercise your rights provided for in the General Data Protection Law, please contact us through our Responsible Person:

Personal Responsible for Data at GJACINTHO

Name: Carolina Rocha Jacintho

Email: lgpd@gjacintho.com.br

CHANGES TO THIS PRIVACY POLICY

This privacy policy may be reviewed regularly and we may make changes to it at any time, without prior notice.

In order to inform you of the changes in this Privacy Policy, we will change the review date in the bottom of this page.

The new Privacy Policy shall apply as of this date of review. Therefore, we encourage you to periodically review this Privacy Policy so you can be informed of how we are protecting you information.

QUESTIONS, DOUBTS AND COMPLAINTS

If you have complaints or are not satisfied with the way we treat your personal data, or if you have doubts or worries with regards to privacy and the treatment of your personal data, please forward them to our Responsible Person at lgpd@gjacintho.com.br.