Privacy Policy

Versão em português

This English version is provided for convenience. In case of any conflict, the Portuguese version prevails.

This Privacy Policy explains how Panucci, Severo e Nebias Sociedade de Advogados (“PSNA”, “we” or “us”), enrolled with the Brazilian taxpayer registry (CNPJ) under No. 57.989.173/0001-00, with offices at Alameda Lorena, 638, 4th floor, Jardim Paulista, São Paulo/SP, Brazil, 01424-002, processes personal data as a controller under Brazilian Law No. 13,709/2018 (the General Data Protection Law, “LGPD”).

This Policy applies to:

• PSNA’s website at psna.com.br and www.psna.com.br, in all of its versions (including the new version of the website, once published) and languages;
• PSNA’s Page on LinkedIn and PSNA applications that connect to LinkedIn through LinkedIn’s official application programming interfaces (APIs), used to publish PSNA content on the Page and to display it on our website; and
• restricted areas of PSNA’s platform (such as app.psna.com.br), which are accessed only by PSNA members and authorized persons.

This Policy does not apply to data processed in the course of providing legal services to our clients. Such data is protected by attorney professional secrecy under Brazilian Law No. 8,906/1994 and governed by the applicable engagement agreements. It also does not apply to third-party websites and services, including LinkedIn itself, which have their own policies.

3.1. Data you send us

When you use the contact form on our website or e-mail us, we process your name, your e-mail address, the content of your message and any other information you choose to include. Please do not send confidential information or sensitive personal data through these channels before PSNA confirms it is able to assist you.

3.2. Browsing data

When you visit our website, we automatically collect technical data such as IP address, date and time of access, pages visited, referring website, browser type, operating system and device. Part of this data is collected through cookies and similar technologies (Section 6), including Google Analytics.

3.3. LinkedIn-related data

PSNA uses LinkedIn APIs to publish content on PSNA’s LinkedIn Page, retrieve the links to those posts, display them on PSNA’s website and monitor the Page’s performance. In this context, we may process:

• data of PSNA members who administer the Page: basic LinkedIn account identification (name, member identifier and e-mail address) and the access tokens they authorize, used solely to operate the integration;
• Page content and metrics: PSNA posts and metrics such as impressions, clicks, reactions, comments, shares and follower count, generally in aggregate form; and
• data of LinkedIn members who interact with the Page: when you comment on or react to a PSNA post, LinkedIn may make the public information of that interaction available to us (such as name, headline and comment text), which we use solely to manage the Page and respond to interactions.

We do not sell data obtained from LinkedIn, do not use it for targeted advertising, do not build profiles of LinkedIn members and do not combine it with data from other sources to identify individuals. Data obtained from LinkedIn is handled in accordance with LinkedIn’s API terms of use and deleted when no longer needed, upon the data subject’s request or when LinkedIn so requires. You may revoke at any time, in your LinkedIn account settings, any permissions granted to PSNA applications.

3.4. Data of restricted area users

To provide access to restricted areas, we process identification and authentication data (name, corporate e-mail address and Microsoft account identifiers) and usage and security logs.

When we rely on legitimate interest, we assess whether the processing is necessary and respects your legitimate expectations and rights. You may object to such processing through the channel indicated in Section 12.

We share personal data only to the extent necessary, with:

• technology providers acting on our behalf, such as hosting and infrastructure (Hostinger and Amazon Web Services), e-mail, authentication and storage (Microsoft) and audience analytics (Google);
• LinkedIn, regarding the content we publish on PSNA’s Page and the interactions made on LinkedIn itself, which LinkedIn processes under its own privacy policy; and
• public authorities, when required by law, regulation or court order.

We do not sell or rent personal data.

Cookies are small files stored in your browser. Our website uses:

• strictly necessary cookies, for the operation and security of the website; and
• analytics cookies, from Google Analytics, to measure statistically how the website is used.

We do not use advertising cookies. You may block or delete cookies in your browser settings and prevent collection by Google Analytics with Google’s official opt-out add-on (tools.google.com/dlpage/gaoptout). Blocking strictly necessary cookies may affect how the website works.

Some of our providers (such as Amazon Web Services, Microsoft, Google and LinkedIn) may process data outside Brazil, including in the United States and the European Union. In such cases, the transfer complies with art. 33 of the LGPD and the regulations of the Brazilian National Data Protection Authority (ANPD), with safeguards such as appropriate contractual clauses.

• contact messages: for as long as necessary to address the request and, if no further relationship follows, for up to 5 (five) years, for the potential exercise of rights;
• website access logs: for 6 (six) months, as required by the Brazilian Internet Civil Framework, or longer if so ordered or requested by an authority;
• data obtained from LinkedIn: for as long as necessary for the purpose and within the limits of LinkedIn’s API terms of use; access tokens are discarded when the authorization is revoked or expires; and
• restricted area user data: for as long as access lasts and, thereafter, for the period required by legal obligations and for security purposes.

At the end of the retention period, data is deleted or anonymized, except as permitted by art. 16 of the LGPD.

We adopt technical and administrative measures to protect personal data, such as encryption in transit (HTTPS), access control with strong authentication, audit logs and access restricted to those who need the data. No system is completely secure; if a security incident that may cause relevant risk or harm occurs, we will notify the ANPD and the affected data subjects as required by law.

Under art. 18 of the LGPD, you may request:

• confirmation of the existence of processing and access to your data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of unnecessary or excessive data or data processed in breach of the law;
• portability of your data to another provider;
• deletion of data processed based on consent and information about the possibility of withholding consent;
• information about the entities with which we share your data;
• withdrawal of consent; and
• objection to processing based on another legal basis, in case of non-compliance with the LGPD.

To exercise these rights, write to the channel indicated in Section 12. We may ask for information to confirm your identity. You may also file a petition with the ANPD (www.gov.br/anpd).

Our website and PSNA’s LinkedIn Page are not directed to individuals under 18 (eighteen) years of age, and we do not knowingly collect data from children or adolescents.

Questions, requests and complaints about this Policy or about the processing of your personal data, including communications addressed to the data protection officer (art. 41 of the LGPD), may be sent to contato@psna.com.br.

We may update this Policy to reflect changes to the website, integrations or legislation. The current version will always be available on this page, with the update date indicated at the top.