Privacy Policy
BGR Asset Management Ltda., enrolled with CNPJ under No. 48.730.767/0001-00, with address at Avenida das Nações Unidas 12.901, CENU, Tower West, Offices 1602,16th floor, Brooklin Novo, Zip Code 04578-910 (“BGR”), cares about the privacy and protection of individuals’ personal data, and, for this reason, prepared this Privacy Policy with the aim to clarify the practices to be adopted regarding the treatment of the holder’s personal data (“Holder”) to which BGR will have access, particularly those that will be collected and/or provided through the website www.bgrasset.com.br (“Website”). The Holder must read this Privacy Policy thoroughly and carefully before submitting any information to BGR, either through the Website or otherwise.
Personal Data Collected
By carrying out its corporate activities, BGR may have access to some personal data that may identify the Holder, including, without limitation, name, e-mail address, telephone number and any other information that may be collected and/or provided (“Personal Data”), as follows:
a) Personal Data provided by the Holder: through the Website or in any other way in order to: (i) access BGR’s developments (e.g., images of the Holder and/or their identification document); (ii) send queries, complaints or comments to BGR (e.g., “Contact Us” or “IR Contact”) or; (iii) sign up to (x) receive information through an electronic message (i.e., “Sign up for Mailing”), or (y) participate in financial results disclosure webcasts; or, also, to (iv) participate in the selective processes or contracting for the supply of goods or services, rental spaces, partnerships, sponsorship, among others, BGR will collect Personal Data and other information that the Holder chooses to provide, which will be handled pursuant to this Privacy Policy and the applicable law. The Holder must ensure the truthfulness and accuracy of all Personal Data provided, assuming the responsibility arising therefrom and committing to keep them duly updated.
b) Personal Data collected automatically: Depending on the access to BGR developments and/or the Website, the following information will be collected for security and/or statistical purposes or to manage the Website and identify any problems: (i) images obtained by internal electronic monitoring and surveillance systems; (ii) name of Internet service and access providers; (iii) means of access to the Website (e.g., type of browser, operating system and device used); (iv) IP address; as well as (v) the geographic location, date and time of access (vi) activity performed on the Website and the page(s) accessed before or after the Website. Cookies may also be sent to the device used by the Holder for the purposes of improving the Website’s performance as well as customizing the access experience. The Holder is free to block such cookies, it being understood that such blocking, however, may prevent the provision of customized access and potentially the operation of certain functions of the Website.
c) Personal Data collected from third parties: BGR may also collect Personal Data from the Holder through third parties that ensure that consent has been obtained for such provision, or that the Holder has made such provision public. BGR hires third parties, such as Google Analytics, to analyze the use of the Website or to assist in the processing and management of data, hosting, technical support and other services used by BGR to manage the Website or customize your experience. Such partners may automatically collect information about the Holder’s use of the Website, such as IP address, type and version of the Internet browser, pages viewed, time spent on pages, links accessed and conversion information. Moreover, BGR hires third parties to manage its internal electronic monitoring and surveillance systems, which capture images of those who access its developments in order to monitor such access and ensure security.
Purposes of the Treatment
Personal Data collected by BGR will be used for the following purposes: (i) to operate the Website; (ii) to better understand the Holders’ needs, concerns and interests, including those who use the Website, as well as to develop and improve the content included on the Website or in any other way; (iii) to enable communication in case of need for support, address requests/complaints or obtain feedback, as well as to contact, select and eventually hire job applicants, suppliers of goods or services or other partners; (iv) to send notices and/or additional information regarding BGR or the Website; (v) to improve the Website’s usability and interactivity; (vi) to prepare statistical analyses through the anonymization of Personal Data pursuant to the applicable legislation; (vii) to carry out communication and/or marketing campaigns; (viii) to comply with the applicable laws or regulations; (ix) to carry out the Holder’s financial, legal and compliance analysis, if and when applicable; (x) to allow access to BGR ‘s developments; and/or (xi) to monitor access and ensure the security of those accessing BGR’s developments. BGR may also be asked to provide or disclose Personal Data stored by it, fully or partly, to respond to or comply with orders from competent authorities, as well as to investigate and/or adopt any measure against a suspected or actual breach of this Privacy Policy, the Terms and Conditions or the applicable legislation. In the latter case, BGR undertakes to provide only the minimum necessary information so as to respond to a given request.
Storage and Term
BGR’s headquarters is in Brazil and all Personal Data collected will be stored: (i) if in physical format, at BGR ‘s headquarters; and (ii) if in electronic format, on BGR’s servers and/or on the servers of the external cloud service provider located in Brazil contracted by BGR; or on servers used by third parties contracted to manage BGR’s electronic monitoring and surveillance systems. BGR and its suppliers maintain and process Personal Data pursuant to this Privacy Policy and other applicable data protection laws. Once BGR no longer needs to process Personal Data under this Privacy Policy or after the Holder’s specific request to eliminate them, BGR shall eliminate and/or anonymize the Personal Data, subject to the applicable legislation. For more information on where and how long your Personal Data is stored, as well as on the elimination and transferability rights, the Holder may contact politicadeprivacidade@bgrasset.com.br and BGR will respond within a reasonable time period and according to the applicable law.
Sharing
BGR does not sell or transfer Personal Data, except as set forth in this Privacy Policy and/or in the applicable legislation. BGR does not disclose Personal Data to third parties, unless: (i) there is an express request or authorization from the Holder, or to individuals who demonstrate legal authority to act on their behalf (such as agents); (ii) Personal Data must be provided to comply with the applicable legislation or a search warrant, subpoena and/or court or administrative ruling; (iii) it is necessary to fulfill an agreement with the Holder or to resolve disputes/complaints or to protect the rights of BGR, its employees, customers or partners; (iv) it is necessary to deal with emergencies, unexpected events or force majeure; or (v) Personal Data are necessary for BGR partners to carry out functions on behalf of BGR, subject to the limits of this Policy and the applicable legislation. In any case, as controller of the Personal Data, BGR will remain liable for the treatment carried out by its partners, except for circumstances beyond its reasonable control.
Security
BGR will take all reasonable measures to safeguard Personal Data collected, which shall be stored in a secure environment and protected following physical, technical and administrative procedures normally used to protect this type of information. Access to Personal Data is restricted to authorized persons who need such access, and these persons are also required to comply with this Privacy Policy.
Rights of the Holder
To the extent allowed by the applicable law, Holders may contact BGR to exercise their right to: (i) confirm the existence of Personal Data treatment; (ii) access Personal Data; (iii) correct incomplete, inaccurate or outdated Personal Data; (iv) anonymize, block or eliminate Personal Data that is unnecessary, excessive or treated without complying with the applicable legislation; (v) transfer Personal Data to another service or product provider, subject to trade and industrial secrets; (vi) eliminate Personal Data treated with the holder’s consent; (vii) obtain information about the sharing of Personal Data; (viii) obtain information about the possibility of not giving consent and the consequences therefrom; (ix) revoke the consent pursuant to applicable legislation. To this end, the Holder may contact us via the email address politicadeprivacidade@bgrasset.com.br and BGR will respond within a reasonable time period and pursuant to the applicable legislation.
Hyperlinks
BGR does not endorse, sponsor, recommend or accept any responsibility for any content or resource made available on third-party websites to which this Privacy Policy does not apply, even if the Holder has been directed to these pages through links made available on the Website, which is why, when being redirected to external pages, the Holder should consult the respective terms of use and privacy policy before using and/or providing any information. The use of such third-party websites is at your own risk and BGR will not be responsible for any loss or damage actually or allegedly caused by or as a result of your trust in a third-party website.
Amendments
This Privacy Policy may be updated occasionally, and the current version will always be available on the Website so that the Holder may consult it. Accessing and using the Website and/or maintaining a relationship with BGR after any amendments to this Privacy Policy will represent the Holder’s acceptance of such amendments.
Contact
In case Holders have any complaints, queries and/or comments on this Privacy Policy or on the way BGR processes its Personal Data, they may get in contact through the email politicadeprivacidade@bgrasset.com.br and BGR will respond within a reasonable time period and according to the applicable law.
