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Amsel & Ara Privacy Policy ("Policy")

Updated on 11/19/2024

1. About this Policy

The objectives of this Policy are:

(i) To establish guidelines that ensure and reinforce Amsel & Ara's commitment to complying with applicable data privacy and personal data protection laws, particularly the General Data Protection Law (“LGPD” – Federal Law No. 13.709/2018) and the General Data Protection Regulation (“GDPR” – European data protection law);

(ii) To inform about how personal data collected by Amsel & Ara on its website is processed;

To ensure transparency for the data subjects whose personal data may be used during its activities, thereby reinforcing its commitment to ethics and security in its operations.

2. About us

Amsel & Ara is an international specialized consultancy firm with offices in São Paulo and Berlin. Our work encompasses the delivery of strategic solutions for companies across various sectors, connecting global knowledge with local needs. We combine expertise in finance, nature-based solutions, carbon, sustainability, ESG, corporate governance, and innovation to assist clients in implementing responsible practices aligned with regulatory and market trends, promoting sustainable development and long-term value creation.

Amsel & Ara takes a proactive approach to personal data privacy and ensures that necessary measures are taken to protect privacy and security during your experience on our website and with our services, as explained in this Policy.

3. Personal Data Processing

Amsel & Ara, a private legal entity, is regularly constituted under the form of Dryad Ltda., with its headquarters at Av. Faria Lima, 1739 - Box 276, ZIP Code: 01452-001, São Paulo – SP, registered with CNPJ/ME under No. 42.389.527/0001-08.

Amsel & Ara acts as an independent data controller in relation to your personal data on our website.

Unless expressly informed, Amsel & Ara does not process sensitive personal data. In the event that processing of sensitive personal data becomes necessary, relevant information regarding the processing of such data will be provided, and a request will be made for your express consent, as applicable under the terms of the LGPD and GDPR.

4. Who is Amsel & Ara's Data Protection Officer?

Marianna Laranjeira, available at hello@amsel-ara.com

Please contact our Data Protection Officer if you have any questions regarding how Amsel & Ara processes your personal data or if you have any requests, as per this Policy.

5. Who is this Policy intended for?

Amsel & Ara collects and processes only the minimum necessary personal data to fulfill its purpose and only uses this data for the purposes for which it was collected. This Policy is intended for:

6. Users of the Amsel & Ara website.

Any person accessing our website.

7. How does Amsel & Ara use your personal data, and for what purposes?

The personal data we collect may be used for the following purposes: (i) Communication: responding to inquiries and providing information about our services; (ii) Marketing: sending updates, newsletters, or promotional materials (with your consent); (iii) Analysis and improvement: monitoring and analyzing website performance to improve user experience; and (iv) Legal compliance: fulfilling legal and regulatory obligations as applicable.

Below are the types of personal data that Amsel & Ara processes, where we collect this data, the reasons for processing it, and the corresponding legal bases described in Articles 7 and/or 11 of the LGPD.

These legal bases ensure the legitimacy of Amsel & Ara’s use of your data in accordance with the LGPD. If you have any questions or disagree with a specific legal basis, please contact the Data Protection Officer using the channels provided in Section 2.

8. Users of the Amsel & Ara website:

Amsel & Ara may collect personal browsing data through cookies on the website, including IP address, geographic location, browser type, and pages visited on our site. In this case, the purpose of processing is to enhance the user's experience on the website. Additionally, the legal basis will be consent for non-essential cookies.

9. Sharing and International Transfer of Personal Data

Amsel & Ara may transfer your data to its offices abroad, particularly its representation in Berlin, Germany, but also in other countries, provided it is strictly necessary to fulfill the intended purpose. In this case, we will take all necessary measures to ensure confidentiality, data protection, and information security, in compliance with applicable laws.

Amsel & Ara does not share your personal data with third parties, except in the following circumstances and only when necessary to fulfill the data collection purpose: (i) Service providers: we may share information with partners and suppliers who assist us in operating the website and providing our services, ensuring they comply with the same privacy obligations; and (ii) Legal requirements: We may share personal data to comply with a legal obligation, regulatory requirement, or court order.

Additionally, Amsel & Ara may be required to share your personal data with judicial and administrative authorities. We will take all necessary measures to ensure that this sharing is done only when strictly necessary, always ensuring, where possible, confidentiality, data protection, and information security in full compliance with the LGPD and GDPR.

10. Duration of Personal Data Processing

Amsel & Ara will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, unless required for legal, contractual, or regulatory compliance, enabling accountability, responding to requests from competent authorities, or defending against legal or administrative claims, as permitted by law. After this period, the data will be deleted or anonymized.

11. Data Subject Rights

You may exercise any of the rights listed below with Amsel & Ara at any time and through the channels indicated below:

(a) Confirm whether Amsel & Ara processes any personal data about you.

(b) Access. Access your personal data processed by Amsel & Ara, generally through a physical or digital copy.

(c) Information. Be informed about the public and private entities with whom Amsel & Ara has shared or from whom it has received your personal data.

(d) Correction. Correct incomplete, inaccurate, or outdated data about you.

(e) Anonymization. Anonymize, block, or delete personal data about you that you believe to be unnecessary, excessive, or processed in non-compliance with the LGPD or GDPR by Amsel & Ara.

(f) Portability. Transfer your personal data to third parties, which currently depends on regulation by the National Data Protection Authority (“ANPD”). In any case, we can provide you with an electronic copy of your data that allows its use by third parties, provided we maintain a direct contract with you.

(g) Revocation. Revoke any consent you have provided to Amsel & Ara for processing your data.

(h) Deletion. Delete your personal data stored with us after you have revoked your consent for Amsel & Ara to process your data.

(i) Objection. Be informed about the consequences of refusing consent requested by Amsel & Ara. We inform you from the outset that you are free to withhold consent from Amsel & Ara, regardless of the purpose of the request. You are also guaranteed the right to object to the processing of your personal data based on any other legal basis than consent, provided you believe that Amsel & Ara is not complying with the LGPD.

(j) File a complaint against Amsel & Ara with the ANPD, if Amsel & Ara does not meet your request within the time frame provided by the LGPD.

When exercising your rights, we may need to request some proof of your identity. This is to protect your personal data and prevent fraud with your information.

The LGPD and GDPR also guarantee your right to review decisions made solely on the basis of automated processing of your personal data that may affect your interests. Additionally, the LGPD and GDPR guarantee your right to receive specific information about the criteria and procedures used to make these decisions. However, Amsel & Ara does not make any decisions based solely on automated processing of personal data, and therefore, these rights do not apply.

12. Security

Amsel & Ara adopts security levels that meet legal requirements for personal data protection. As such, Amsel & Ara is committed to applying technical and organizational measures to protect personal data from unauthorized access and from situations of destruction, loss, alteration, communication, or dissemination of such data, including access restriction, regular backups, and firewalls.

13. Modifications

Amsel & Ara may make changes to this Policy at any time and without prior notice. Amsel & Ara emphasizes the importance of periodically accessing this Policy. To assist you, the date of the last update is provided at the beginning of this Policy.