1. What data do we collect about you and for what purpose?

Montgomery collects, including via the website, and uses some of your personal data, in order to enable the provision of legal services.

Whenever you access and use our website, Montgomery will automatically receive and store information, including your IP address, cookies, which will be related to the personal information you provide.

2. Consent

It is based on your consent that we process your personal data. Consent is the free, informed and unequivocal expression by which you authorize the Montgomery to process your data.

Therefore, in accordance with the LGPD, your data will only be collected, processed and stored with prior and express consent, demonstrating the commitment to transparency and good faith of Montgomery towards its users/customers, following the relevant legislative provisions.

When using the services of Montgomery and provide your personal data, you are aware of and consent to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them.

At any time and without custo, you may revoke your consent.

It is important to note that revoking consent to data processing may result in the inability to adequately provide the service, as well as the proper performance of some website functionality that depends on the operation. These consequences will be communicated in advance.

3. What are your rights?

A Montgomery ensures its users/customers their data subject rights under the LGPD. Therefore, you can, free of charge and at any time, by requesting it to the Data Protection Officer indicated in item 11 below:

1. Confirm the existence of data processing, in a simplified way or in a clear and complete format.
2. Access your data, being able to request them in a legible copy in printed form or electronically, secure and reputable.
3. Correct your data by requesting editing, correction or updating.
4. Limit your data when it is unnecessary, excessive or processed in non-compliance with legislation through anonymization, blocking or deletion.
5. Request the portability of your data, through a report of registration data that Montgomery processes about you.
6. Delete your data processed based on your consent, except in cases provided for by law.
7. Revoke your consent, disallowing the processing of your data.
8. Inform about the possibility of not providing your consent and the consequences of refusal.
9. How can you exercise your rights as a holder?

To exercise your rights as a holder, you must contact the Montgomery through the following available means:

• Email: dadoslgpd@montgomery.adv.br
•  Phone: + 55 11 4096-4000

In order to ensure your correct identification as the holder of the personal data object of the request, we may request documents or other proof that may prove your identity. In this case, you will be informed in advance.

5. How and for how long will your data be stored?

Your personal data collected by Montgomery will be used and stored for the time necessary to provide the service and the corresponding prescriptive period after said service provision or for the purposes described in this Privacy Policy to be achieved, considering the rights of data subjects and controllers.

In general, your data will be kept for as long as the contractual relationship between you and  Montgomery persist and the corresponding prescriptive period. Once the personal data storage period ends, it will be deleted from our databases or anonymized, except in the cases legally provided for in the LGPD, namely:

I – Compliance with a legal or regulatory obligation by the controller;

II – Study by a research body, ensuring, whenever possible, the anonymization of personal data;

III - transfer to a third party, provided that the requirements for the treatment of data in this law have been respected; ou

IV – Exclusive use by the controller, its access by a third party being prohibited, and provided that the data is anonymized.

That is, personal information about you that is essential for complying with legal, judicial and administrative determinations and/or for exercising the right of defense in judicial, arbitration and administrative proceedings will be maintained, despite the exclusion of other data.

The storage of data collected by Montgomery reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions capable of guaranteeing the confidentiality, integrity and inviolability of your data. In addition, we also have security measures appropriate to the risks and control access to stored information.

6. What do we do to keep your data safe?

To keep your personal information secure, we use physical, electronic and managerial tools designed to protect your privacy.

We apply these tools taking into account the nature of the personal data collected, the context and purpose of the treatment and the risks that any violations would generate for the rights and freedoms of the data subject collected and processed.

Among the measures we have adopted, we highlight the following:

• Only authorized persons have access to your personal data;
• Access to your personal data is only granted after a commitment to confidentiality, whether established contractually or by virtue of the Statute of the Bar;
• Your personal data is stored in a safe and sound environment.

Montgomery is committed to adopting the best practices to prevent security incidents. However, it is important to emphasize that no website is entirely secure and risk-free. Despite all our security protocols, problems may occur that are solely the fault of third parties, such as cyberattacks. hackers, or also as a result of the negligence or recklessness of the user/customer.

In the event of security incidents that may generate significant risk or damage to you or any of our users/customers, we will notify those affected and the National Data Protection Authority (ANPD) about the incident, in accordance with the provisions of the LGPD.

7. Who can your data be shared with?

In order to preserve your privacy, Montgomery will not share your personal data with any unauthorized third party.

In addition, there are also other hypotheses in which your data may be shared, which are:

I – Legal determination, application, requisition or court order, with competent judicial, administrative or governmental authorities.

II – In the case of corporate movements, such as mergers, acquisitions, spin-offs, transformations and incorporations, automatically

III – Protection of the rights of (simplified business name) in any type of conflict, including those of a judicial nature.

7.1. international data transfer

Some of the third parties with whom we share your data may be located or have facilities in foreign countries. Under these circumstances, your personal data will be subject to the LGPD and other Brazilian data protection laws.

In this sense, Montgomery is committed to always adopting efficient cybersecurity and data protection standards, in the best efforts to guarantee and comply with legislative requirements.

If you agree with this Privacy Policy, you agree with this sharing, which will be given in accordance with the purposes described in this instrument.

8. Cookies or browsing data

Montgomery makes use of Cookies, which are text files sent by the platform to your computer and stored there, containing information related to website navigation. In short, Cookies are used to improve the user experience.

By accessing our website and consenting to the use of Cookies, you acknowledge and accept the use of a navigation data collection system using Cookies on your device.

 You may, at any time and at no cost, change permissions, block or refuse access to Cookies. However, the revocation of consent of certain Cookies may prevent the proper functioning of some platform features.

To manage the cookies of your browser, just do it directly in the browser settings, in the management area of Cookies.

9. Changing this Privacy Policy

The current version of the Privacy Policy was formulated and last updated on: (August 1, 2021).

We reserve the right to modify this Privacy Policy at any time, mainly depending on the adequacy of any changes made to our website or in the legislative sphere. We recommend that you review it frequently.

Any changes will take effect as of their publication on our website and we will always notify you of any changes that have occurred.

By using our services and providing your personal data after such modifications, you consent to them.

10. Responsibility

Montgomery provides for the responsibility of agents involved in data processing processes, in accordance with the LGPD.

We undertake to keep this Privacy Policy updated, observing its provisions and ensuring compliance.

Furthermore, we are also committed to seeking technical and organizational conditions that are safely capable of protecting the entire data processing process.

If the National Data Protection Authority -ANPD requires the adoption of measures in relation to the processing of data carried out by Montgomery, We commit to following them.

10.1 Disclaimer

As mentioned in Chapter 6, although we adopt high security standards to prevent incidents, no website is entirely risk-free. In this sense, Montgomery is not responsible for:

I – Any consequences arising from the negligence, recklessness or malpractice of users in relation to their individual data. We guarantee and are solely responsible for the security of the data processing processes and the fulfillment of the purposes described in this instrument.

We emphasize that the user is responsible for the confidentiality of access data.

II – Malicious actions by third parties, such as hackers, unless proven to be culpable or deliberate conduct by Montgomery.

We emphasize that in the event of security incidents that may generate significant risk or damage to you or any of our users/customers, we will notify those affected and the National Data Protection Authority (ANPD) about the incident and will take the necessary measures.

III – Inaccuracy of the information entered by the user/client in the records necessary for the use of the services Montgomery Any consequences arising from false information or information entered in bad faith are the sole responsibility of the user/customer.

11. Data Protection Officer

A Montgomery provides the following means for you to contact us to exercise your rights as a data subject: email encarregadolgpd@montgomery.adv.br and/or telephone +55 11 4096-4000.

If you have any questions about this Privacy Policy or about the personal data we handle, you can contact our Personal Data Protection Officer, through the following channels:

Name of the person in charge: Flávio Igel (CPF under no. 370.018.638-07)

Person in Charge's Email: encarregadolgpd@montgomery.adv.br