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We, at PRYOR GLOBAL, are committed to safeguarding your privacy and protecting your data. The purpose of this document is to clarify what information is collected from users (“you”) through our website – http://www.pryorglobal.com – and respective services provided and as well as how this data is used.
To offer our services, PRYOR GLOBAL, through its website, applications and systems, from the equipment where it is installed or being used and the devices synchronized with it, collects different data and information, aiming, in particular, to provide you with an increasingly better experience. PRYOR GLOBAL acknowledges that your privacy is very important and, therefore, we take all possible measures to protect it.
In this sense, this Privacy Notice (“Notice”) aims to assist in understanding what information we may collect, how this information may be used, with whom the information may be shared, and what the rights of the holders are regarding the protection of your personal data.
This Privacy Notice applies when you use our services that involve online and offline data collection, including personal data collected by our various services and channels, including websites, apps, PRYOR GLOBAL pages on third-party social media, among other related ones. Our users may choose, in certain cases, the data that we collect, use and share, as described in this Privacy Notice.
This Notice is divided as follows for an easy understanding:
1. How do we collect personal data?
2. What types of data does PRYOR GLOBAL collect?
3. What is data collected for and what legal bases apply?
4. Who does PRYOR GLOBAL share your data with?
5. What are the rights of data subjects?
6. How long will PRYOR GLOBAL store the data?
7. How does Information Security work at PRYOR?
8. Data Protection Officer (DPO)
9. Changes to the Privacy Notice
1. How do we collect personal data?
This Notice applies to the personal data we collect from or about you, in order to ensure transparency regarding the sources of collection and what data is collected, we identify, in detail, the information, according to the services provided:
Website: Personal information is collected when the user interacts on our website by completing the contact form. This personal information includes first and last name, email, telephone, company name.
The user of our portal is under no circumstances obliged to provide any personal data in order to browse the pages of the website, so that any information is provided freely and spontaneously. It is only necessary to collect basic data when the user wants to return his contact. The personal information collected is accessible only to those who need to know it in order to carry out relevant activities, respecting the purpose for which it was provided.
Service Channels: the user can contact us by phone, email, WhatsApp or even physically, at our addresses. Personal data is collected in order to identify the user, as well as to fulfill your request. These may include, but are not limited to, first name, last name, company name, corporate email and corporate phone number. In addition to these, we collect any personal data that is spontaneously informed by the user.
Cookies: personal data may be collected through cookies. For more information, consult our Cookies Policy, which is available at our website.
Communication, disclosure and publicity: the user may also choose to receive marketing emails including newsletters, communication about the launch of new free materials or new products from PRYOR GLOBAL, events and satisfaction surveys, after filling out the contact form available on the website.
Data related to the provision of our services: to enable the exercise of our activities related to the representation of foreign companies, we process data that is shared and controlled by our clients, information provided by filling out forms, as well as other public information and made available by third parties, such as the Central Bank of Brazil, Federal Revenue, Judiciary and Registry of Commerce, as needed. You can check our service at https://pryorglobal.com/representacao-de-empresas-estrangeiras/
For the provision of outsourcing services, we treat data that is shared and controlled by our clients, as well as information provided by filling out a form, with details of the company's registration information with public bodies, information on foreign shareholders, information regarding the type of operation of the company and volume of monthly transactions.
For the provision of services related to the management of benefits and intermediation of corporate insurance and its subsequent administration, personal data of our clients’ collaborators, beneficiaries and third parties are processed, among others: registration data, such as full name, Identity Card (RG) and Individual Taxpayer's Register (CPF), address, telephone, e-mail, financial data, such as branch and checking account number, credit card number, contracting data, such as vehicle license plate and National Registry of Motor Vehicles (Renavam) number, and sensitive data such as health data, genetic or biomedical data. In specific and isolated cases, we also request sensitive data such as: date of birth, gender and marital status.
For such activity, the collection and processing of personal data of minors may be carried out, in the events legally provided for, in the case of dependents, beneficiaries or clients.
For the provision of DPO (Data Protection Officer) outsourcing services, we process personal data that is shared and controlled by our clients. These data include, but are not limited to full name, company information, National Corporate Taxpayer's Register (CNPJ), address, representative's CPF, address, nationality, passport, among others necessary for the service to be performed.
Platform “Portal Pryor”: personal information is collected when the user (client, collaborators/lawyer or business partner) accesses the platform, by a previously registered login and password, to request services related to the legal representation process, such as signing documents and financial flow release. By providing the information, the user agrees, through acceptance, to the Terms and Conditions of Use of the platform.
Events: personal information, such as name, telephone number and contact e-mail, may also be collected in physical or digital media by our collaborators employed at fairs, exhibitions and events promoted by PRYOR GLOBAL, or in those in which it participates as a sponsor or exhibitor.
Candidates for job openings: personal information from candidates for job openings is collected by filling out a form available at our website. These data are name, email and other professional information mentioned in a document sent by the candidate, by uploading a resume.
Employees: we collect personal data from our collaborators and candidates for jobs at PRYOR GLOBAL, whose data is forwarded by the candidates themselves through the contact email. This data is necessary to execute the employment agreement, register the employee and comply with labor legislation.
It is worth mentioning that all data that we collect are used for the provision of our services. Therefore, all data and information about you are processed as confidential, and we will only use it for the purposes described herein and authorized by you, so that you can fully use our services, mainly, with the purpose of always improving your experience as a user.
Social Media: PRYOR GLOBAL also uses Social Media to communicate and interact with its clients through third-party websites, such as LinkedIn, Facebook, Instagram and YouTube. These third-party websites are an Internet-based technology that is not operated or controlled by PRYOR. By interacting with, sharing or “Liking” the PRYOR GLOBAL page on LinkedIn, Facebook, Instagram, YouTube or other social media, you may reveal certain personal information to PRYOR GLOBAL or third parties.
We use “social buttons” to allow our users to share or bookmark web pages. These are buttons for third-party social media sites that may record information about your activities on the Internet, including this site. Please review the respective terms of use and privacy policies of those sites to understand exactly how they use your information, such as opting out of receiving or deleting such information. The amount of personal information visible will depend on your own privacy settings on LinkedIn, Facebook, Instagram, YouTube and other social media.
2. What types of data does PRYOR GLOBAL collect?
The amount and type of information collected by PRYOR GLOBAL varies according to the use you make of our services provided by each of our Group companies. We collect different data if you are visiting our website, using our software, using the services of clients of our software or our PRYOR GLOBAL services.
3. What data is collected for and what legal bases are applied?
We list below the purposes and legal bases of PRYOR GLOBAL's data processing:
Purposes | Legal Basis |
Fulfill the agreement established with our clients. | It will be determined by our client, as controller of personal data. |
Comply with terms and conditions set forth in the contract. | Necessary for performance of a contract in which the holder of personal data is a party. |
Recruitment and assessment of adherence to the job vacancy. | Justified based on our legitimate interests to ensure that we recruit the right employees. |
Facilitate communication with you (including in emergencies and to provide you with requested information). | It is justified on the basis of our legitimate interests to ensure adequate communication and emergency management in the organization. |
Compliance with legal requirements. | Necessary for compliance with a legal obligation to which we are subject to. |
Monitor your use of our systems (including monitoring your use of our website and any apps and tools you use). | It is justified on the basis of our legitimate interests to avoid non-conformities and protect our reputation. |
Social listening (identifying and analyzing what is being said about PRYOR GLOBAL on social media [only publicly accessible content] in order to understand market trends and the needs of our stakeholders and, in this way, improve our services.) (identificando e analisando o que está sendo dito sobre a PRYOR GLOBAL nas mídias sociais [somente conteúdo acessível publicamente] a fim de perceber tendências de mercado e as necessidades de nossos stakeholders e, dessa forma, melhorar nossos serviços.) | It is justified on the basis of our legitimate interests in protecting our assets and our brand on social media. |
Improve the security and operation of our website, application, networks and information. | It is justified on the basis of our legitimate interests to ensure that you will have an excellent user experience and that our networks and information are secure. |
Offer our products and services to you (unless you have shown objection to such treatment). | It is justified on the basis of our legitimate interests to ensure that we can conduct and improve our business. |
Manage employee benefits. | It is justified based on the employee's consent, if it is in their interest to receive a certain benefit. |
Delivery of necessary information to government agencies. | For compliance with a legal obligation. |
We only rely on our legitimate interest for specific purposes. This processing of personal data does not, in any way, override the interests, rights and freedoms of the subjects.
4. With whom does PRYOR GLOBAL share your data?
Since it is an online platform, PRYOR GLOBAL may operate jointly with other companies in a wide range of activities, including to provide location features, advertisers, sponsors and commercial partners, online and offline, besides the tools for disclosure and analyzing performance. Therefore, we reserve the right to share your information, including data on location, registration and interests, with the companies below, whenever possible, anonymously, as to preserve at most your privacy.
PRYOR GLOBAL does not practice the disclosure of information that can identify you. These data are for exclusive and internal use to achieve the purposes expressed in the previous item.
We do not rent, sell or transfer your personal data to anyone, except the partner companies listed below: We may share your personal data with third parties, in the following cases:
• Upon court decision or request by government oversight bodies;
• Data transferred to public bodies to comply with current legislation, for example personal data contained in electronic invoices or data from our collaborators necessary for the payment of Brazilian Social Security Institute (INSS) or Guarantee Fund for Length of Service (FGTS);
• Data transferred to financial institutions to provide payment options to our clients or to pay wages to our collaborators and providers;
• Data shared with partners, operators and service providers who participate, directly or indirectly, in the development of PRYOR GLOBAL's commercial activities, such as business representation services in Brazil, legal services (consulting and legal advice, including tax and labor areas), paralegal services, legal representation services, document signing services, services related to the liquidation of companies, accounting services (including services for reviewing financial statements as well as services related to tax bookkeeping and compliance with ancillary tax obligations, such as, for example, advising foreign companies on rendering accounts and providing tax documents to the competent authorities), financial services (which include, but are not limited to: billing, credit, collection, accounts payable, cash flow and bank control services), management and treasury services, payroll management services (by payroll and Human Resources solutions as well as BPO services), insurance companies, reinsurance companies, health operators and other intermediaries operating in the insurance market, DPO (Data Protection Officer) outsourcing services, data storage and processing, verification of registration information, targeted advertising platform, advertising and marketing as well as general advertising services, security and performance monitoring, auditing, collection, payment processing, customer service, email delivery, repair and maintenance services, order and transaction processing and fulfillment, research, data retention and data processing;
• Data transferred for the purpose of agreement performance or for the protection of PRYOR GLOBAL's interests in any type of conflict, including lawsuits;
• Other PRYOR GLOBAL companies: the personal data collected may also be shared with other companies of the Group, which undertake to use the information for the same purposes and with the same guarantees indicated in this Notice.
• In the case of corporate operations such as a merger, acquisition, transformation, spin-off, or a partial or total sale of assets, we may share, disclose or transfer all data from the subjects to the successor organization.
Some of the service providers mentioned above may be located abroad and, in this case, PRYOR GLOBAL adopts additional safeguards to ensure an adequate level of protection of personal data, in accordance with the provisions of the relevant Brazilian legislation.
5. What are the rights of the data subjects?
Personal data Subjects have certain rights with regard to their personal data and can exercise them by clicking here to access the Data Subject Access Request (DSAR) or by email: [email protected].
Subjects' rights are:
• Confirmation that personal data is being processed;
• Access to personal data, in accordance with applicable legislation;
• Correction of incomplete, inaccurate or out-of-date information;
• Data portability;
• Exclusion of data, when these are processed based on the consent of the Subject or when the data is unnecessary, excessive or processed in breach of applicable legislation;
• Requesting information about shared data use;
• Revocation of consent when applicable.
PRYOR GLOBAL will always evaluate the best way to comply with the request to exercise any of its rights. However, PRYOR GLOBAL may fail to comply with your request, in whole or in part, in specific situations protected by law, such as, for the fulfillment of a legal obligation or an agreement it has with you. We emphasize the importance of keeping your personal data accurate and up-to-date. To do so, always keep PRYOR GLOBAL informed if your personal data changes or is incorrect. For security reasons, requests made through the email [email protected] will only be responded if we are sure of the user's identity. Therefore, we may request additional data or information to confirm the identity and authenticity of the subject. This data and information will be protected during the storage period and will be deleted after the legal period for the eventual regular exercise of rights has passed. In cases where PRYOR GLOBAL is the Personal Data Operator, requests will be forwarded to the Controller so that he can evaluate and decide on the measures to be taken.
6. How long will PRYOR GLOBAL store the data to?
The termination of the processing of personal data will occur in the following cases: (a) when the purpose for which the personal data was collected is achieved, and/or the personal data collected is no longer necessary or relevant to achieve such purpose; (b) when the Subject requests the deletion of his data; and (c) when there is a legal determination to this effect, and (d) when the end of processing is determined by the Controller.
In cases of personal data processing termination, with the reasons established by applicable law or this Privacy Notice, personal data will be deleted.
7. How does Information Security work at PRYOR?
To ensure that your personal information is secure, we communicate our privacy and security guidelines to PRYOR GLOBAL employees, and we strictly follow precautionary measures regarding privacy within the company.
We strive to protect your Personal Information, and those entrusted to us by our clients, by physical, technical and organizational measures to reduce the risks of loss, misuse, unauthorized access, disclosure and improper alteration of this data.
With the purpose of ensuring your privacy and protection of your personal data, PRYOR adopts the best information security and secure development practices on the market, that is, we design our products and services to promote protection of your data and where you can manage your information directly. Combined with this concept, we adopt encryption practices in passwords and other critical information, TLS for transfer of data between applications, engagement of cloud services with safety certifications and labels, such as ISO 27001, SOC 1 and SOC 2/SSAE 16/ISAE 3402 and PCI DSS, systems monitoring 24/7, edge firewall with features of IDS (Intrusion Detection System), anti-malware, anti-phishing, content control and VPN.
We strive to protect the privacy of your account and other personal data of yours that we keep in our records but, unfortunately, we cannot ensure total safety. Unauthorized entry and use of the account, hardware or software failure and other factors may compromise the safety of your personal data at any time, thus please help us to keep a safe environment for all. In addition to adopting good security practices in relation to your account and your data, if you identify or become aware of something that compromises the security of your data, please contact us through the service channel available, indicated in item 8 below.
8. Personal Data Officer (DPO) PRYOR GLOBAL provides below the contact details of the Data Protection Officer (DPO), who is responsible for meeting any and all requests by the subjects or the National Authority, which are related to personal data.
For any questions, requests or complaints regarding the processing of personal data, please contact our Personal Data Officer:
DPO EXPERT – (www.dpoexpert.com.br)
Responsible: Rafael Susskind
contact: [email protected]
If, despite our commitment and efforts to protect your data, you feel that your data protection rights have not been met, please, contact our DPO. In addition, you have the right, at any time, to file a complaint directly with the National Data Protection Authority, if you believe that the rights over your personal data have been infringed.
9. Changes to the Privacy Notice
Although our Privacy Notice has been presented in a clear, concise and objective manner, do not hesitate to consult PRYOR's DPO if you have any doubts about this important document or even about the personal data processing activities we carry out. Since we are always trying to improve our services, this Privacy Notice may be updated. Therefore, we recommend that you visit this page periodically to be aware of the changes. In case of relevant changes that require a new consent from you, we will publish such update and request a new consent from you.
Therefore, PRYOR GLOBAL reserves the right to update or modify this Notice, at any time and without prior notice. However, we will always publish the new revised version on our website. If there are changes in the way we treat personal data, you will be informed to check if you intend to continue using our services.
Essential Cookies (Necessary) grounded on our legit interest | ||||
Name | Provider | Feature | Term | Type |
Cookielawinfo-checkbox-necessary | Pryorglobal.com | Sets if the user accepted the cookie consent box. | 1 year | HTTP |
Cookielawinfo-checkbox-non-necessary | Pryorglobal.com | Sets if the user accepted the cookie consent box. | 1 year | HTTP |
Elementor | Pryorglobal.com | Used in the context with the website´s WordPress theme. The cookie allows the weboste-s owner to implement or alter the website´s content in real time. | Persistent | HTML |
Test_cookie | Doubleclick.net | Used to verify if the user´s browser offers cookies support. | 1 day | HTTP |
Analytical Cookies grounded on your consent | ||||
Name | Provider | Feature | Term | Type |
_ga | Pryorglobal.com | Registers the exclusive ID used to generate statistic data on how the user uses the website. | 2 years | HTTP |
_ga_# | Pryorglobal.com | Used by Google Analytics to collect data on the number of times that the user has visited the website, as well as the date of the first and most recent browsing. | 2 years | HTTP |
_gat | Pryorglobal.com | Used by Google Analytics to control the request rate. | 1 day | HTTP |
_gid | Pryorglobal.com | Register an exclusive ID that is used to generate statistic data on how the user uses the website. | 1 day | HTTP |
_hjAbsoluteSessionInProgress | Pryorglobal.com | This cookie is used to detect the first session of pageview of a user. This is the True/False flag defined by the cookie. | 1 day | HTTP |
_hjFirstSeen | Pryorglobal.com | This is defined to identify the first session of a new user. It storages a true/false value, indicating if this is the first time the Hotjar has seen this user. It is used by recording filters to identify the user´s new sessions. | 1 day | HTTP |
_hjIncludedInSessionSample | Pryorglobal.com | This cookie is defined to know if the user is included in the data sampling defined by the website´s daily session limit. | 1 day | HTTP |
_hjSession_# | Pryorglobal.com | Collects statistics on the user´s browsing on the website, such as the number of browsing, the average time spent on the website, and which pages were read. | 1 day | HTTP |
_hjSessionUser_# | Pryorglobal.com | Collects statistics on the user´s browsing on the website, such as the number of browsing, the average time spent on the website, and which pages were read. | 1 year | HTTP |
Bounce | Adnxs.com | Ascertains if the user leaves the website immediately. This information is used to internal statistics and analysis by the website´s operator. | Session | Pixel |
Cb | Prfct.co | Collects data, such as the user´s IP address, geographic location, and website´s browsing – This information is used for internal optimization and statistics by the website´s operator. | Session | Pixel |
Personalization_id | Twitter.com | The cookie is used by Twitter.com to ascertain the number of users that access the website by means of Twitter´s advertise content. | 2 years | HTTP |
Seg | Adnxs.com | Registers statistic data on the user´s behavior on the website. Used for internal analysis by the website´s operator. | Session | Pixel |
Seg | Prfct.co | Registers statistic data on the user´s behavior on the website. Used for internal analysis by the website´s operator. | Session | Pixel |
Marketing Cookies grounded on your consent | ||||
Name | Provider | Feature | Term | Type |
_ss | Pryorglobal.com | Collects information on the user´s behavior on several websites – This information is used to optimize the relevance of the ad. The cookie also allows the website to ascertain how the user has browsed the website. | 1 day | HTTP |
_ss_referrer | Pryorglobal.com | Collects information on the user´s behavior on several websites – This information is used to optimize the relevance of the ad. The cookie also allows the website to ascertain how the user has browsed the website. | 1 day | HTTP |
_ss_tk | Pryorglobal.com | Collects information on the user´s behavior on several websites – This information is used to optimize the relevance of the ad. The cookie also allows the website to ascertain how the user has browsed the website. | 25 years | HTTP |
_fbp | Pryorglobal.com | Used by Facebook to provide a series of advertising products, such as real time snacks from third parties advertisers. | 3 months | HTTP |
A3 | Yahoo.com | Collects information on the user´s behavior on several websites – This information is used to optimize the relevance of the ad. | 1 year | HTTP |
Anj | Adnxs.com | Registers an exclusive ID that identifies the device of a recurring user. The ID is used to segmented ads. | 3 months | HTTP |
Cs | Prfct.co | This cookie is used to optimize the relevance of the ad collecting users´ data from several websites – This users´ data Exchange is usually provided by a third-party data center or ads exchange. | Session | Pixel |
Fr | Facebook.com | Used by Facebook to provide a series of advertising products, such as real time snacks from third parties advertisers. | 3 months | HTTP |
Getuid | Adnxs.com | This cookie is defined by the website´s audience manager to ascertain the time and frequency of synchronization of the user´s data – the cookie´s data synchronization is used to synchronize and collect data from users of several websites. | Session | Pixel |
I | Openx.net | Registers anonymous user data, such as IP address, geographic location, websites visited and which ads the user clicked on, with the purpose to optimize the ad exhibition based on the user´s movement on websites that use the same ads network. | 1 year | HTTP |
i/adsct | Twitter.com | The cookie is used by Twitter.com to ascertain the number of users that access the website by means of Twitter´s advertise content. | Session | Pixel |
IDE | Doubleclick.net | Used by Google DoubleClick to register and report the user´s actions on the website after seeing or clicking in one of the ads from the advertiser with the purpose to measure the ads efficiency and the top send again ads directed to the user. | 1 year | HTTP |
IDSYNC | Analytics.yahoo.com | Used to identify the user in browsing and devices. This allows the website to present relevant ads to the user – The service is provided by hubs of third parties ads, which facilitate the bid in real time to the advertisers. | 1 year | HTTP |
Koitk | Marketingautomation.services | Collects data on the behavior and interaction of the user to optimize the website and turn the advertising on the website more relevant. | 10 years | HTTP |
Na_id | Addthis.com | Used to recognize the user in the reentry. This allows the website to register the user´s behavior and facilitates the sharing feature of social media provided by Addthis.com | 1 year | HTTP |
Ouid | Addthis.com | Defines an ID´s string to a specific user. This is used to recognize the user in the reentry. This allows the website to register the user´s behavior and facilitates the sharing feature of social media provided by Addthis.com | 1 year | HTTP |
Pa_#_ts | Prfct.co | Used on websites that use the same network to display ads to other advertisers from the network. | 2 years | HTTP |
Pa_uid | Prfct.co | Used on websites that use the same network to display ads to other advertisers from the network. | 2 years | HTTP |
Tr | Facebook.com | Used by Facebook to provide a series of advertising products, such as real time snacks from third parties advertisers. | Session | Pixel |
Uid | Addthis.com | Collects data on the user´s browsing to the website, which pages were uploaded. The data registered are used to directed ads. | 1 year | HTTP |
Usermap | Prfct.co | Collects data on the browsing and behavior of the user on the website. This is used to compile statistic reports and heat maps to the website´s owner. | Session | Pixel |
Uuid2 | Adnxs.com | Collects data on the user´s browsing to the website, such as which pages were uploaded. The data registered are used to directed ads. | 3 months | HTTP |
w/1.0/sd | Openx.net | Registers data on the users, such as IP address, geographic location, and interaction with ads. This information is used to optimize the advertising on websites that use the services of OpenX.net | Session | Pixel |
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