Your privacy is important to us at Passarini Regulatory Affairs. Therefore, we are committed to transparency in the treatment of personal data of our customers and for this reason we are presenting and establishing our Privacy Policy where it will be discriminated to our customers, and users, who access the site of Passarini Regulatory Affairs as the information treated.

This Privacy Policy applies to all individuals who interact with, access or use the Website in any way or who communicate with us through one of Passarini Regulatory Affairs’ customer service channels (“Users”). “Service Channels” are the channels of Passarini Regulatory Affairs that provide customer service, whether through our website, by phone, email, online form, chat or other service channels that may be offered by our company.

Please read this Privacy Policy completely, and if you do not agree, you should not access our site.

1) Definitions

Some nomenclatures that will be used in our Privacy Policy are defined by the General Law of Data Protection, with their respective meanings:

  • Legal Basis for Treatment – The treatment of Personal Data is allowed by LGPD according to the legal bases provided, such as the consent of the Holder, compliance with legal and/or regulatory obligations, the existence of a contract, as well as legitimate interests of those involved.
  • Consent – It is the free, informed and unequivocal manifestation by which the Holder agrees with the treatment of his/her Personal Data for a determined purpose.
  • Personal Data – Is any data related to an identified or identifiable natural person, such as: IP, geolocation, name, RG, CPF, address, telephone, bank account, vehicle data, among others.
  • Sensitive Personal Data – Personal data that includes racial or ethnic origin, religious belief, political opinion, union membership, health or sex life data, genetic or biometric data.
  • Purpose – This is the reason or motivation for the processing of Personal Data.
  • Legitimate Interest – Data processing carried out by the Controller due to an interest of the Controller, other companies or society, without the processing affecting the individual rights and freedoms of the Data Holder.
  • General Data Protection Law (LGPD) – Law No. 13.709 of August 14, 2018.
  • Free Access – The right of the Data Holder to have access to all the information concerning the processing of his/her Personal Data.
  • Security – Means the use of technical and administrative measures to protect Personal Data from unauthorized access and accidental or unlawful destruction, loss, alteration, communication or disclosure.
  • Processing – Is every operation performed with Personal Data, such as: collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation, information control, communication, transfer, diffusion or extraction.
  • Data Holder – The natural person to whom the Personal Data that are processed refer to.
  • Transparency – It is the guarantee, to the Holders, of clear, precise, and easily accessible information on the performance of the processing and respective processing agents, observing commercial and industrial secrets.

Although the sharing of personal data with Passarini Regulatory Affairs is a user’s choice, it is a condition for using the website and for us to provide services through the customer service channels. We therefore recommend that this privacy policy be read carefully.

For the purposes of this Privacy Policy, Passarini Regulatory Affairs acts as controller of the Users’ personal data (art. 5, VI of LGPD).

2) Consent

This Privacy Policy applies to the Passarini Regulatory Affairs website and governs the way we collect and use your personal data.

We request your personal data only when really necessary and in the minimum amount appropriate to provide you with services. We do this by transparent, lawful, secure means, and with your knowledge and consent. We also let you know why we are collecting and how your data will be used.

By agreeing to our Privacy Policy, you will be expressing your consent, in accordance with the provisions of art. 8 of LGPD – General Law of Data Protection. Your consent may be revoked at any time upon your manifestation, ratifying the processing carried out under the support of the previously manifested consent, as per art. 8, § 5 of the LGPD.

In principle, Passarini Regulatory Affairs does not process sensitive personal data (personal data concerning racial or ethnic origin, religious belief, political opinion,
membership of a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data when linked to a natural person) – Article 5, II of the LGPD – or of minors.

In the case of minors, it will be essential that our company be formally informed with specific and prominent consent given by at least one of the parents or legal guardian (art. 14, § 1 of LGPD).

3) Information Collected

We collect your information when:

  • Stay Tuned Form
    This form is on our website, and is filled out by you. When submitting your data through this form, you are asked to enter your e-mail address.
  • Contact Form
    This form is on our website, and is filled out by you. When you submit your data via this form, you are asked to enter your name, e-mail address, and phone number.
  • Login
    This form is on our website, and is filled out by you. When submitting your data through this form, you are asked to enter your e-mail address and password. This password is the sole responsibility of the user who requested access and created it.
  • Cookies
    We use these cookies to allow us to recognize the computers that access our site. Through them we can recognize your preferences and make personalized content available. (Details are described further below under Cookie Policy)
  • Google Analytics
    It is one of the most widespread and trusted analytics solutions on the Web, to help us understand how you use the site and how we can improve your experience. (Details are described further below under Cookie Policy). Links for external sites
  • We may have links to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites and cannot accept responsibility for their respective privacy policies. Passarini Regulatory Affairs is not responsible for these websites and content and does not share, endorse, monitor, validate or accept how these websites or content storage tools collect, process and transfer your personal and private information. We recommend that you consult the respective privacy policies of such websites to properly inform yourself about the use of your personal
    information by other websites or other tools.

3) Purpose of Information Use

Information that is submitted by customers and users via the contact form is collected and retained for as long as necessary to provide the requested service.

The information generated through cookies and collected through Google Analytics is intended to enable special and individualized treatment for each customer. Through this information, we seek to improve our customer profile and statistical information about access to our site, respectively.

Also to comply with legal and regulatory obligations including reporting to the competent authorities adverse events or issues related to safety and quality, which eventually includes internal audit processes, investigation procedures and instruction in any judicial, administrative or arbitration proceedings and to protect the rights and interests of Passarini Regulatory Affairs or third parties.

Thus, through these communication channels we can get to know our customer better and provide services that meet their needs, expectations, and preferences.

4) Security, Storage and Data Protection

We take care of your information with security and confidentiality standards, to provide our customers with a safe and reliable environment. We use technology and encryption to maintain the integrity and confidentiality of your information to prevent loss and theft and to protect it from unauthorized access, disclosure, copying, use or modification.

Data will be stored in accordance with applicable law and for the period necessary or permitted in view of the purposes for which the Personal Data was collected, as set forth in this Privacy Policy. The criteria used to determine our retention periods include, but are not limited to:

(i) duration of the relationship between the holder and Passarini Regulatory Affairs;

(ii) any legal or regulatory obligation requiring maintenance; and (iii) applicable statute of limitations, as provided by law.

In the role of Data Operator or Data Controller, Passarini Regulatory Affairs hosts your site on servers with highly reliable technology. Your information is stored on a secure server, and whenever there is a need to identify or provide information, the transmission of data between your computer and the Passarini Regulatory Affairs site will be through a secure connection. In addition, all analyses performed on your individual information will also be done by electronic processing, and the results presented will always be statistical summaries, in which your name will never appear.

Passarini Regulatory Affairs uses its best efforts to preserve the security and privacy of Users’ data, but we also encourage Users to take appropriate steps to protect themselves, such as maintaining the confidentiality of all user names and passwords.

5) Information Sharing

Passarini Regulatory Affairs does not share, trade, or transfer your personally identifiable information reported by you on this site publicly or with third parties.

We may disclose your information to comply with and enforce legal, regulatory and contractual obligations, as well as for the protection and regular exercise of rights by you and Passarini Regulatory Affairs, as there are several situations in which the processing of personal data is permitted regardless of your consent. These are the so called legal grounds for data processing, provided for in Art. 7 of the LGPD in the cases below:

  • When the data is indispensable for the controller to comply with legal or regulatory obligations (art. 7, II);
  • When the shared data processing is necessary for the execution of public policies (art. 7, III);
  • So that research organizations can conduct studies, always observing the anonymization of sensitive personal data (art. 7, IV);
  • For the regular exercise of rights, including contracts and judicial, administrative and arbitration proceedings (art. 7, VI);
  • In case of protection of the life or physical safety of the data subject or third parties (art. 7, VII);
  • For health protection, in procedures that must be performed by health professionals/health authorities (art. 7, VIII);
  • To ensure that the data holder is safe and prevented from fraud, always observing the right to information and transparency guaranteed by law (art. 7, IX).

The personal data we collect may be stored and processed in any country in which we do business or in which our service providers are located, in accordance with a particular purpose. Passarini Regulatory Affairs will take appropriate steps to ensure that international transfers are carried out in compliance with applicable law.

6) Maintenance, Deletion and Correction of Information

Request to update, correct or delete your information collected in accordance with this Privacy Policy may be requested through our contact channels.

In accordance with art. 18 of the LGPD, at any time, upon express request, you have the right to:

  • Confirmation that Personal Data are being processed (art. 18, I). • Access to Personal Data (art. 18, II).
  • Corrections of incomplete, inaccurate or outdated Personal Data (art. 18, III).
  • Anonymization, blocking or deletion of Personal Data deemed unnecessary, excessive or treated in violation of the law (art. 18, IV).
  • Portability of Personal Data to a third party, provided this does not affect our industrial and commercial secrets (art. 18, V).
  • Deletion of Personal Data processed on the basis of consent, to the extent permitted by law (Art. 18, VI).
  • Information about the entities to which the Personal Data has been shared (art. 18, VII).
  • Information about the possibility of not providing consent and consequences of refusal (art. 18, VIII).
  • Revocation of consent (art. 18, IX).

We emphasize that we may keep information for compliance with legal or regulatory obligations; study by research organization, guaranteed, whenever possible, the anonymization of personal data; transfer to a third party, provided that the requirements of data processing provided in this law are met; or exclusive use of the controller, forbidden its access by third parties, and provided that the data is anonymized and to protect and exercise the rights of Passarini Regulatory Affairs and the data subjects (art. 16, I, II, III and IV of LGPD).

You have the right to object to the processing of your personal data for direct marketing purposes. If you object, we will no longer process your personal data for this purpose.

7) Cookies Policy

  • What are Cookies?
    Cookies are small text files that may or may not be added to the browser of the device used to access the Sites. These files store and recognize data from your browsing to ensure that the Sites function properly and to provide you with a better browsing experience.
  • How do we use Cookies?
    The Passarini Regulatory Affairs website uses cookies to enable us to recognize the computers that access our site. Through them we can recognize your preferences and make personalized content available. These “cookies” are secure, private, anonymous, do not transmit viruses, and are used only for the benefit of our customers. They are also used to measure certain traffic patterns on the site, so that we can understand browsing interests and behaviors.
  • Browsers and cookies
    In general, browsers (Internet Explorer, Microsoft Edge, Chrome, Firefox) are already configured to allow the creation of “cookies”. You can also specify whether or not you want to be asked by the program before a particular site
    places a “cookie” on your computer’s hard disk.
  • Allow or disallow the creation of cookies
    Likewise, you can choose whether or not to allow your browser to accept the Passarini Regulatory Affairs “cookie” or any other “cookie”, and specify different settings for different security zones. It is worth pointing out that the “cookies”, once accepted, act as your “business card”, that is, they are a way to facilitate the identification of users.
    In this way, we access information from cookies in order to provide you with a better and more targeted service in accordance with our cookie usage policy.
  • Cookies we define
    We may use cookies in the following ways:
    • Site preference cookies
      To provide you with an optimal experience on this site, we have provided functionality to set your preferences for how this site runs when you use it. To remember your preferences, we need to set cookies so that this information can be called up whenever you interact with a page that is affected by your preferences.
    • Third-Party Cookies
      In some special cases we also use cookies provided by trusted third parties. The following section details which third-party cookies you may encounter through this site.
      This site uses Google Analytics, which is one of the Web’s most widespread and trusted analytics solutions, to help us understand how you use the site and how we can improve your experience. These cookies can track things like how long you spend on the site and the pages you visit, so that we can continue to produce content.
      For more information about Google Analytics cookies, please see the official Google Analytics page.
      Third-party analytics are used to track and measure the use of this site so that we can continue to produce compelling content. These cookies can track things like the time you spend on the site or the pages you visit, which helps us understand how we can improve the site for you.
      Periodically, we test new features and make subtle changes to the way the site looks. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience while on the site, while we understand which optimizations our users appreciate the most.
      As our site is accessed, it is important for us to understand statistics
      about how our visitors access the site, and so this is the kind of data that these cookies will track. This is important for you, because it means that we can make accurate business forecasts that allow us to analyze our advertising costs.
      For more information about Google Analytics, please see Google’s official Privacy FAQ.

You can disable, through your Internet browser settings, the automatic collection of information through some technologies, such as cookies and caches, as well as on our own website, specifically regarding cookies. However, the User should be aware that if these technologies are disabled, some features offered by the site, which depend on the processing of this data, may not work properly.

8) Privacy Policy Revision

Changes to this privacy policy may be made at the discretion of Passarini Regulatory Affairs at any time and changes are updated automatically on the Passarini Regulatory Affairs website and with the date of change explicitly stated on the website.

9) Contact

If you have any questions or need further clarification about this privacy policy and terms of use, you can contact us using the information below.
Email: [email protected]
This policy is effective as of April/2021.
Passarini Regulatory Affairs