Privacy Policy

PURPOSE
This Privacy Notice establishes the provisions and conditions for the use of the main website https://www.Vittorepartners.com.br/ of Vittore Partners.

This Notice is the property of Vittore Partners for internal use and publication on its website, and must not be reproduced or shared without prior authorization.

SCOPE OF APPLICATION
For the purposes of applicable data protection and privacy legislation, especially the General Data Protection Law (Law No. 13,709/2018, as amended, hereinafter referred to as “LGPD”), Vittore Partners will disclose this Privacy Notice on its website. Accessing and browsing the Vittore Partners website by third parties indicates their full awareness, understanding, and acceptance.

DEFINITIONS AND TERMINOLOGIES
Without prejudice to the definitions under the LGPD, for the purposes of this Notice, the following terms shall have the meanings below:

CONTROLLER: natural or legal person, public or private, responsible for decisions regarding the processing of personal data.
COOKIES: small text files stored on the user’s device by the internet browser, widely used to make websites function generally or more efficiently and to provide information to website owners.
PERSONAL DATA: information related to an identified or identifiable natural person.
DATA PROTECTION OFFICER (DPO): person appointed by the controller and operator to act as a communication channel between the controller, data subjects, and the National Data Protection Authority (ANPD).
LGPD: General Data Protection Law (Law 13,709/2018).
OPERATOR: natural or legal person, public or private, who processes personal data on behalf of the controller.
DATA SUBJECT: natural person to whom the personal data processed refers.
PROCESSING: any operation performed with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.
USER: any natural person accessing the Vittore Partners website.

DESCRIPTION

4.1. General Guidelines
Vittore Partners is the controller of the personal data it collects on its website. This means it is responsible for making decisions about how personal data will be processed, according to the terms set forth herein.

4.2. Vittore Partners Website
The Vittore Partners website aims to present information about the services and programs offered to our clients. Additionally, the website provides access to our internal channels, as well as news and information about our company.

4.3. Use of the Website
Users shall not perform or allow reverse engineering, translation, decompilation, copying, modification, reproduction, renting, sublicensing, publishing, disclosing, transmitting, lending, distributing, or otherwise improperly use any functionalities of the Vittore Partners website.

In case of violation of this Website Use Policy, the user shall indemnify Vittore Partners for all losses and damages, including moral or competitive damages, expenses, or other charges caused by such violation, including, but not limited to, attorney’s fees and legal costs.

4.4. Principles
All personal data processing operations carried out by Vittore Partners are guided by the following principles:

Purpose: personal data processing shall be conducted to fulfill a legitimate, specific, explicit, and duly informed purpose.
Adequacy: processing shall only occur if compatible with the informed purposes.
Necessity: personal data processing shall be limited to the minimum necessary to achieve the intended purposes.
Free access: facilitated and free consultation regarding the form and duration of processing, as well as the entirety of personal data, shall be guaranteed.
Data quality: processed personal data shall be accurate, clear, relevant, and up to date.
Transparency: information relating to data processing shall be easily accessible, clear, and precise, allowing users to know how data is processed, the purposes, form, duration, and with whom their data may be shared.
Security: technical and administrative measures shall be adopted to protect personal data from unauthorized access and accidental or unlawful situations such as distribution, alteration, and loss.
Prevention: measures shall be adopted to prevent damage occurrences.
Non-discrimination: personal data shall never be processed for discriminatory, unlawful, or abusive purposes.
Accountability and compliance: measures capable of proving compliance with the law and the effectiveness of such measures in protecting personal data shall be adopted.

4.5. Types of Personal Data Collected
Vittore Partners may collect and process the following personal data through its website https://www.Vittorepartners.com.br/onix/:

Vittore Onix Contact (website contact form): name; email; phone; information in attached files; message.
To process job applications and/or program participation, the collection of personal data such as signature, ID numbers (RG and CPF), date and place of birth, email and/or residential addresses, marital status, photos/images/audio/videos, gender, education information, names and family data, contact phone numbers, profession, individual publications, and social media registration data, professional registration may be required.

Sensitive personal data may be collected according to the specific job requirements and when necessary for health evaluation during admission stages, such as disabilities, access needs, health information, union or association participation (political, religious, among others).

Sources of personal data collection may include the candidate or references, via CVs, application forms, interviews, employer or colleague references, among others.

4.6. Purpose of Data Processing
The personal data collected will be used to carry out recruitment and selection processes.

4.7. Sharing of Personal Data
The commitment to user privacy also extends to partners and third parties contracted. Vittore Partners shares personal data only when strictly necessary to fulfill the purposes described above. Therefore, information may be shared with third parties to enable the provision of our services and programs.

Moreover, personal data may be shared with judicial and administrative authorities whenever there is a legal or regulatory requirement.

Users may be redirected via links to other portals that may collect their personal data; in such cases, users are responsible for reading and accepting the respective privacy policies. Vittore Partners is not responsible for third-party policies, content, or services outside its domain.

4.8. How Vittore Partners Stores User Data
User personal data will be securely stored in its systems and servers for the time necessary to perform its activities. Vittore Partners retains personal data as long as there is a need for processing to execute services and programs, as well as to comply with legal or regulatory requirements. When processing purposes are fulfilled, personal data will be securely discarded in accordance with internal policies and legal obligations.

4.9. International Data Transfer
Vittore Partners may transfer user personal data outside Brazil to third parties abroad, including cloud service providers. When international transfer is necessary, Vittore Partners will adopt appropriate technical security measures to ensure data protection in compliance with applicable privacy and data protection laws.

4.10. Security Measures
Throughout the processing of user personal data, technical and administrative measures are implemented to maintain security and prevent unauthorized access, accidental or unlawful destruction, loss, alteration, communication, or any form of improper or unlawful processing.

4.11. User Rights
Under the LGPD, users have the following rights regarding their personal data:

Confirmation of the existence of processing – any data subject has the right to confirm whether their personal data is being processed.
Access to data – the data subject has the right to access their data and obtain related information.
Correction of incomplete, inaccurate, or outdated data – the data subject has the right to maintain their data updated and accurate.
Anonymization, blocking, or deletion – the data subject may request these actions when data is unnecessary, excessive, or processed contrary to the LGPD.
Data portability – the right to obtain their personal data in a structured format to be transmitted to another service or product provider (another data controller).
Deletion – the right to delete personal data processed based on consent, except when legal or regulatory obligations allow processing, transfer to third parties, or when data is anonymized for exclusive controller use.
Information about sharing – the right to know which public and private entities personal data was shared with.
Refusal to provide consent – the right to refuse to provide consent and be informed of any consequences.
Revocation of consent – the right to revoke consent at any time.

Users must be attended to within a reasonable time as stipulated by the LGPD and related regulations. For data access or processing confirmation requests, the deadline is 15 (fifteen) days.

Rights may be exercised via the email governanca@vittorepartners.com.br.

4.12. Cookies
Vittore Partners uses cookies to collect and store information regarding users’ personal preferences when visiting the site. This information consists of data related to browsing preferences and pages visited, collected automatically through one or more cookies or anonymous identifiers.

These data are used to improve browsing experience by aligning the site’s presentation with users’ interests. Vittore Partners ensures compliance with applicable data protection principles, and data collected will not be used for purposes other than those informed.

Internet browsers generally accept cookies by default, but users can adjust settings to block them. It may be necessary to refresh the page for changes to take effect.

Changes in cookie settings may affect how users interact with the site, potentially causing errors in some functionalities.

4.13. Intellectual Property
Vittore Partners holds the copyrights to all information provided on its website, including intellectual property and related rights such as databases, trademarks, and registration requests.

Unless expressly permitted otherwise, the name, trademark, and logo of Vittore Partners must not be used by website users. Information on the site must not be copied, reproduced, republished, downloaded, posted, or transmitted to third parties for commercial purposes.

Users who wish to temporarily store or display Vittore Partners’ website information on their device may do so for personal use only.

4.14. Limitation of Liability
Vittore Partners is not responsible for the availability or quality of internet access services provided by third parties or the connection quality of devices to the internet.

Furthermore, Vittore Partners is not liable for damages caused by breaches of privacy or data security during user device internet connections via third parties.

All content on the Vittore Partners website is provided “as is” without warranties of any kind, express or implied, including warranties of fitness for a particular purpose.

4.15. Amendments to Terms and Conditions of Use
Vittore Partners reserves the right to modify any part of the website and this Privacy Policy at its sole discretion at any time. If amended, the new version will be promptly published and accessible at the same location as this Policy.

4.16. Illegal, Invalid, or Unenforceable Provisions
If any provision of this Privacy Policy is deemed illegal, invalid, or unenforceable, it will be severed and excluded from the document. The remaining provisions will remain in effect and binding.

4.17. Governing Law
This Privacy Policy is governed by Brazilian law and the jurisdiction of Brazilian courts.

4.18. Questions and Clarifications
If you have any questions regarding the use and processing of personal data by us, you may send a request to governanca@vittorepartners.com.br.

4.19. Data Protection Officer Contact Information
Name: Bruno Lourenço
Email: governanca@vittorepartners.com.br

REFERENCES
– General Data Protection Law (Law 13,709/2018).