Vargas Consultancy, based in Lisbon, Portugal (the “Vargas Consultancy”, “We” or “Office”), understands the importance of the duty to respect the privacy and security of the information of its clients and the general public. (“Users” or “You”), who use the website https://www.vargasconsultancy.pt (“Website”). Therefore, the use of such information is carried out in accordance with national data protection regulations, including Law No. 13,709/2018 (General Data Protection Law – “LGPD”).

It is not possible to make payment on the website without having access to this personal data. In this way, the processing of personal data is a condition for using the website.

Check the contents of this Policy:

1. What personal data we collect and process
2. Why we collect and process this personal data
3. When we delete personal data
4. Who else will have access to personal data and why
5. What are your rights in relation to this personal data
6. How we store and protect your personal data
7. You need to provide your consent to use your personal data as described in this policy.
8. Third Party website
9. Changes to this Policy
10. How to make a complaint

According to Law No. 13.709/2018, Vargas Consultancy is considered the “Operator” of your personal data within the context of providing legal services, which is why the information presented throughout this document concerns only the data processed by Vargas Consultancy in the context of the platform. If, after reading this Policy, you still have any questions or, for any reason, need to communicate with us about matters involving your personal data, you can contact us through the channels below:

contato@vargasconsultancy.pt

Personal data of data and payment: Vargas Consultancy only receives or otherwise collects the following information related to Users at two times, (i) when accessing the website, through pixels, (ii) and when paying for the consultation , which implies that the following data will be collected, albeit at different times:

• Name;
• Complete Address;
• Payment method details;
• email;
• telephone.
• access date,
• IP adress,
• estimated location,
• device type,

Device information: We may also collect device information, such as IP, date and time of access to the website through tracking pixels. The use of cookies by the website is restricted to statistical analysis of the use of the Platform, without any connection to the IP or other personal data of the user.

2- Why we collect and process this personal data

 We use Users’ personal data for the following purposes:

Given Purpose

Personal Registration Data • For consultation payments to be made directly through the platform.

Device Information • To comply with legal obligations and measure our reach.

Vargas Consultancy does not use Users’ personal data for any other purpose or purpose, in addition to the purposes described above.

3- When we delete personal data

 We structure the Website and our operations so that your personal data is not kept in an identified manner for longer than necessary. That is, we keep personal data only for the period in which it is necessary for the purposes described above, if we are required by law or for the regular exercise of our rights.

 We may keep personal data anonymously, that is, without being or being able to be related to a User, for longer periods.

4- Who else will have access to personal data and why

  We may occasionally share our users’ personal data with the different branches of Vargas Consultancy and/or with the third parties identified below, hired to support us in carrying out the purposes mentioned in item 2 above.

 Likewise, the Wix website hosting platform will also have access to the data, as they will have traffic through this platform, which is already subject to the General Data Protection Law (LGPD) – Law No. 13,709/2018.

 Some of these branches and these third parties may be located outside Brazil. If your personal data is transferred to another country, we will take the measures required by law, both in Brazil and abroad, to ensure that they remain protected, however, we warn you to keep in mind that when using the Website and providing us with your personal data they may be sent to other countries.

 Third Shared Data Type Purpose of Sharing

Our external marketing provider, the hosting platform (Wix) and our customer service department •Personal registration data • To guide our marketing strategy and ensure the best customer service delivery

Judicial, police, governmental authorities or other third parties with whom we are required by law, regulatory rule or court order to share the Data •Personal registration data

• Device Information • In the event of a request, by means of a court order or legal or regulatory obligation, to disclose to judicial, police or governmental authorities certain personal data about our Users.

5- What are your rights in relation to your personal data?

Under the General Data Protection Law (LGPD) – Law nº 13.709/2018 –, you have the right to:

I- confirmation that we have processed your personal data;
II- access to your personal data;
III- correction of personal data that is incomplete, inaccurate or out of date;
IV- anonymization, blocking or deletion of unnecessary, excessive or processed personal data in violation of the provisions of the LGPD;
V- portability of your personal data to another service or product provider, observing our commercial and industrial secrets, after regulation by the National Data Protection Authority;

saw. deletion of personal data processed based on your consent, except in the cases of conservation of personal data provided for in the LGPD;

VII- information about who we share your personal data with;

VIII. information about the possibility of not providing your consent and the consequences;

IX- revocation of your consent to the processing of your personal data, when the personal data is processed on the basis of your Consent (see item 7 below);

X- opposition to treatment that violates the LGPD.

You can exercise any of the above rights by sending an email to contato@vargasconsultancy.pt

Before we respond to a request to exercise the rights mentioned above, we may ask you to provide us with certain information to confirm your identity.

6- How we store and protect your personal data

 We store your personal data securely in the entire Vargas Consultancy system, in Brazil and abroad. It is worth mentioning that we adopt the best technical and administrative practices to protect personal data from unauthorized access, destruction, loss, alteration, communication or any form of inappropriate or illicit treatment.

However, at the same time, no platform is completely secure. If you have any concerns or suspects that your personal data is at risk, for example if someone has had unauthorized access to your personal data, please contact us immediately.

7- Do you need to provide your consent for Vargas Consultancy to use personal data as described in this policy?

The LGPD discriminates against 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 bases for data processing”.

Thus, if you choose to use our Website, in some cases we may collect and process your personal data regardless of your consent (if there is a “legal basis” provided for in the LGPD that allows us to do so). In other cases we will ask for your consent to use your personal data.

At the moment, through this policy, the Vargas Consultancy website collects your consent only to carry out consultations and payments. If there is any change in the processing of personal data and it becomes necessary to collect your consent, you will be informed (see item 9 below) so that your consent is duly collected under the terms of the LGPD.

As a resource for our Users, we may provide links to other websites on the Internet. Vargas Consultancy is not responsible for these websites and content, nor does it share, subscribe, monitor, validate or accept the way in which these websites or content storage tools collect, process and transfer your personal and private information.

Therefore, we recommend that you consult the respective privacy policies of such websites and platforms to inform yourself about the use of your information and personal data by other websites or other tools.

Vargas Consultancy reserves the right to change the provisions of this Policy at its discretion and at any time.

Whenever we materially change this Policy, those changes will be valid, effective and binding after: (1) they are posted on the Vargas Consultancy website; (2) be sent by email to Users and/or (3) be communicated in any other way to Users.

The User must check the updated version of this Policy each time he visits the Website.

In cases where changes to this Policy imply changes in our personal data processing practices that depend on the consent of Users (see item 7 above), Users will be asked to consent to the new terms of this Policy after the change so that may continue to use the Platform and receive the Services.

10- How to make a complaint

You can file a complaint using the Vargas Consultancy contact details provided above.

You can also send a message to the National Data Protection Authority.