Objective
This Privacy and Data Processing Policy aims to demonstrate how São Pedro Capital (“São Pedro Capital” or “we”) collects, uses, and, when applicable, shares your information, always with the commitment to protect your privacy and personal data, establishing rules for data processing, as well as explaining your rights and how to exercise them, under the terms of Law 13.709/18 – General Data Protection Law (“LGPD”).
It is important that you carefully read this Policy, along with any other privacy or processing notices that we may provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how and why we use your data. This privacy notice complements the other notices and does not replace them.
We may periodically change this Privacy Policy. If we make changes, you will be notified through the new date indicated at the end of this document, and in some cases, we may provide you with additional notice (for example, by adding a statement to the homepage of this website).
This Policy applies to all investors, employees, partners, or individuals who have a relationship with São Pedro Capital, as well as to all visitors of this website.
Definitions
(i) Cookies: This website uses various technologies, such as cookies, as described below, to collect information that helps São Pedro Capital understand how the site is used. Specifically, when a user visits the website, São Pedro Capital may automatically collect various statistical usage data from the website, which can be analyzed to enhance web design and functionality, increase São Pedro Capital’s ability to serve investors and their accounts, and personalize communications with investors regarding products and services.
A “cookie” is a small file of letters and numbers stored on a user’s computer, tablet, mobile, or other device when they visit a website. Cookies contain information that is transferred to a device or read on it, allowing websites to recognize such devices and store certain information, such as user preferences.
If you are not comfortable with the idea of your data being used in this way, most computer systems and browsers offer settings and privacy options, such as disabling cookies or opting for the “Do Not Track” feature. This website does not override the functioning of these settings or options. However, if you do not wish to provide such information through the website or if you choose to use the privacy features mentioned above in your computer system or browser, you may not be able to access certain content, features, services, products, or benefits of this website.
The use of cookies by São Pedro Capital does not identify individual visitors of the website to third parties, nor does it allow third parties to collect personally identifiable information about your online activity while visiting non-affiliated websites.
(ii) Personal Data: It is information related to a natural person that allows direct or indirect identification. Considered personal data are: name, ID, CPF (Taxpayer Identification Number), gender, date and place of birth, phone number, residential address, GPS location, photograph, health record, bank card, income, payment history, consumption habits, leisure preferences; IP (Internet Protocol) address and cookies, among others.
(iii) Sensitive Personal Data: It is any data about racial or ethnic origin, religious belief, political opinion, union membership, or membership in a religious, philosophical, or political organization, health or sexual life data, genetic or biometric data, when linked to a natural person and subject to specific treatment conditions.
(iv) Data Protection Officer: Natural or legal person appointed to act as a communication channel between São Pedro Capital, data subjects, and the National Data Protection Authority (ANPD).
(v) Data Subject: The natural person to whom the Personal Data being processed relates.
(vi) User: Individuals who access the site and/or interact with the activities offered on it.
Information Security
São Pedro Capital restricts access to collected data to employees, agents, contractors, and third parties who need to be aware of such information for the execution of their activities. To protect your personal data, we have implemented security measures compatible with industry practices and standards for an investment manager like ours, in order to prevent your personal data from being accidentally lost, used, or accessed without authorization, altered, or disclosed.
To safeguard your privacy and protect your personal data, São Pedro Capital has a governance program that includes rules of good practices, internal policies, and procedures that establish conditions for organization, training, and mechanisms for supervision and mitigation of risks related to the processing of personal data. São Pedro Capital’s Policies are available on this website.
Information Collection
a) Automatically Collected Personal Data
We collect certain information about visitors to this site automatically when the user accesses or uses this website, including data about their use, such as the type of browser, access times, pages viewed, and their IP address.
We may use this collected information about users for various purposes, such as improving our website and your online experience, understanding which areas and features of our website are popular, counting visits, personalizing our communications to adapt them to visitors, as well as for other internal business purposes.
b) Personal Data Provided by the Data Subject
The information occasionally collected and shared with São Pedro Capital by users will be used exclusively for: (i) contact identification of a potential investor; (ii) no sensitive data will be collected on this site; (iii) data will not be used for commercial purposes and will not be shared with third parties for commercial purposes; (iv) data may be accessed by third parties contracted by São Pedro Capital to comply with legal and regulatory requirements.
São Pedro Capital processes personal data of individuals who have or had any relationship with the company, were or are partners, directors, or employees, and may even share this data with service providers hired for accounting services, solely for the purpose of complying with labor and tax obligations. The partner directors may have their personal data shared with companies that São Pedro Capital intends to engage with in compliance with anti-money laundering regulations.
c) Investment Opportunities
The use of your personal data, provided to us regarding a particular investment opportunity, will be governed by the privacy policy contained in the subscription agreement and documents related to the transaction.
Information Sharing
São Pedro Capital may share data collected about you:
(a) within São Pedro Capital, to the extent permitted by law, to promote and develop our services,
(b) with non-affiliated third parties that provide services to São Pedro Capital, such as fund administration and control, risk analysis, and logical data analysis, for use in relation to the provision of such services,
(c) with competent judicial, administrative, or governmental authorities whenever there is a legal determination, requirement, request, or court order;
(d) for investigation of possible infractions and analysis of AML (Anti-Money Laundering) and compliance with Anti-Corruption and Terrorism Financing Laws;
(e) upon formal request from the data subject;
(f) automatically, in the case of corporate transactions such as mergers, acquisitions, and incorporations.
Notwithstanding the above, São Pedro Capital may freely share aggregated or non-identifiable information, which cannot be used to identify you to third parties.
Data Subject Rights
In compliance with applicable regulations regarding the processing of personal data, São Pedro Capital respects and guarantees your ability to make requests based on the following rights:
i) Confirmation of treatment existence;
ii) Access to data;
iii) Correction of incomplete, inaccurate, or outdated data;
iv) Anonymization, blocking, or elimination of unnecessary, excessive, or lawfully processed data;
v) Portability of data to another service or product provider, upon express request by the User;
vi) Deletion of data treated with User consent;
vii) Obtaining information about public or private entities with which São Pedro Capital has shared your data;
viii) Information about the possibility of the User not providing consent, as well as being informed about the consequences of refusal;
ix) Revocation of consent.
The above rights can be exercised by sending a formal request to the email address [email protected].
If you request the deletion of your Personal Data, it is possible that these will not be promptly deleted, in compliance with Article 16 of the General Data Protection Law, which allows data to be processed for an additional period, including for legal or regulatory compliance.
Retention of Collected Information
The Personal Data collected and activity records are stored in a secure and controlled environment, which may be on our servers located in Brazil, as well as in a cloud server environment, which may require the transfer and/or processing of your data outside Brazil.
These transfers involve only companies that demonstrate compliance with applicable laws, maintaining a level of compliance similar to or stricter than that provided by Brazilian legislation.
We store Personal Data only for as long as is necessary to fulfill the purposes for which they were collected or to comply with any legal or regulatory obligations, or to preserve rights.
After the retention period and legal need have passed, Personal Data will be deleted using secure disposal methods or used in an anonymized form for statistical purposes.
Consent
Your consent is the basis for us processing your personal data. Consent is the free, informed, and unequivocal manifestation by which you authorize São Pedro Capital to process your data.
Therefore, in accordance with the General Data Protection Law, your data will only be collected, processed, and stored with your prior and express consent.
Your consent will be obtained specifically for each purpose described above, demonstrating São Pedro Capital’s commitment to transparency and good faith toward its users/clients, in compliance with relevant legislative regulations.
By using São Pedro Capital’s services and providing your personal data, you are aware of and consenting to the provisions of this Privacy and Data Processing Policy, as well as being informed of your rights and how to exercise them.
At any time and at no cost, you may revoke your consent.
Termination of Data Processing
São Pedro Capital may keep and process the personal data provided for the entire period in which they are relevant to regulatory compliance, in compliance with the regulations established by regulators and the scope of the purposes listed in this document.
Questions or Doubts
If you have any questions regarding the provisions of this Privacy and Data Processing Policy, including the exercise of your rights, please contact the Data Protection Officer of São Pedro Capital, Luciane Gomes, via email: [email protected]
São Paulo, July 2023.