Privacy Policy

General Aspects

This document is the intellectual property of GMX Brazil, hereinafter "us", it cares deeply about the privacy of its visitors, users and users of users, therefore, it is strongly committed to the protection of your Personal Data and full compliance with the requirements arising from of Brazilian Law number 13.709/18 (General Data Protection Law - LGPD) and, when applicable, also international legislation such as GDPR - General Data Protection Regulation.

1. Introduction

GMX Brazil's privacy policy was created for specific purposes, making it applicable only to the electronic address www.gmx-brazil.com. It should be noted that when browsing and/or using the content of this website, you unequivocally and irreversibly agree with the usual procedures regarding the collection, transfer, storage, processing and use of information, as well as Personal Data that is submitted or collected to us, carried out within the scope and terms of this privacy policy. There is still reinforcement in relation to total or partial disagreement, as described in the Terms and Conditions, you will not be able to access or use this website and its content.

2 - Concept

The privacy policy that considers Personal Data as a fundamental pillar, which refers to any information related to an identified or identifiable natural person, directly or indirectly and that intrinsically has the concept of terms of use in relation to privacy, promotes information necessary for understanding and transparency for users to act in full compliance with the procedures that are essential for the full functioning of the website and/or partial agreement regarding qualitative procedures when visiting the GMX Brazil address.

3 - Purpose

This policy aims, for the sake of transparency, to describe the reasons why there is a need to collect Personal Data and to demonstrate the treatment of this data to users, as well as to demonstrate the inherent rights of data holders.

4 - Target audience:

This policy has the nature of establishing, over time, the transparency of the relationship via the web with users and users of users, commercial relationships, opportunities and job offers for young people and experienced professionals who seek replacement in the job market and/or seek changes in their careers and generate access to our BLOG, which aims to relate matters directly or indirectly related to the areas of auditing and consulting in all market niches, compliance, ESG and others that are considered relevant to the sole and exclusive position of the corporate governance of the GMX Brazil, therefore, when it comes to defining the target audience, we have:

- Possible future clients, clients and/or potential clients;

- Visitors;

- Users, users of users and users of the BLOG;

- Third parties in general;

- Candidates for vacancies;

- Senior partners and collaborators;

- Service providers and suppliers; and

- Others.

5 - Collection, treatment and use

Our website was developed and is hosted by the company WIX.COM, a company that, in our view, is in compliance with data protection legislation in Brazil and abroad. WIX.COM provides us with an online platform that we use fundamentally as a demonstration channel for the services offered by GMX Brazil, publish content on our BLOG (which allows the public to interact with the "posts") and make available our contact channels via the web for relationship commercial or employment. Your information may be stored on WIX.COM's firewall-secured server database.

GMX Brazil, due to the fact that it does not operate with financial transaction methods via the website, does not have programming lines defined by the PCI-DSS, managed by the PCI Security Standards Council, which is a joint effort of brands such as Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure secure handling of credit card information by merchants and service providers, so please note that we do not collect financially sensitive data.

The data we collect and file is information that you, the user, add to our website or provide us in any other way, such as BLOG login data and information such as name, telephone number and e-mail to those interested in obtaining proposals for future commercial transactions. therefore not collecting any sensitive data. Data that does not identify users is also collected, but it is essential for generating traffic reports, most visited website pages and interaction information, with exemption from referrals to social networks and other websites when part of the user changes the environment, where the collection is the responsibility of companies other than GMX Brazil. We aim to collect as little data as possible from any and all users. For cases of receiving resumes from candidates for vacancies, the collection and processing of data is in charge of the www.gmx.us platform, which is under United States and European legislation by the United Kingdom when responding to the gmx.co.uk used by Lucas Dias our global CEO and founder of GMX Brazil.

The ones you add on our website or provide us in any other way, aiming to use them for the purpose of providing services, hiring talent or third parties when necessary, defending legal proceedings, complying with the legislation in force in Brazil and abroad, sending invitations , publications, various announcements and data to identify active users (make comments on posts) to ensure that there are no offenses to others or activities that could discredit the brand that will be penalized by banishment without prior notice or right of administrative or legal appeal , as you agree with the terms when entering the website or end your navigation when you disagree with the terms.

For treatment we have legal bases, namely:

Consent - To legitimize the processing of Personal Data of processes in which the Data Holder can choose to be carried out or not.

Compliance with legal or regulatory obligations - In compliance with legal or regulatory requirements, such as in cases of posts that denote possible cases of racism or prejudice, money laundering, ideological falsehood, among others.

Regular exercise of rights - Need for regular exercise of rights in judicial, administrative or arbitration proceedings.

Execution of contracts - For the execution of a contract or preliminary procedures to a contract to which the Holder is a party.

Legitimate Interest - To support services that are of interest to our clients, for example, forensic investigation services or services related to information technology. We also use this legal basis to carry out activities to promote GMX Brazil.

6 - Period of retention of personal data

Personal data will be kept for the time necessary to comply with legal obligations and/or for the regular exercise of our rights, including in a contract and/or for the purposes of auditing our activities.

After the purpose of processing Personal Data has ended, the information will be discarded or allocated to anonymity, following company policies related to the safe disposal of data.

It is important to point out that some personal data processing situations may require the use of algorithms designed to automate certain procedural steps. GMX Brazil guarantees that it uses clear criteria compatible with the General Data Protection Law for automated decisions and already understands the exemption when browsing jointly with third-party websites. It should also be noted that we do not share data in Brazil or abroad.

7 - Cookie Policy

Cookie is a file that contains an identifier (a sequence of letters and numbers) stored by browsers, which is then sent back to the server when a page is requested from the server. Cookies typically do not contain information that personally identifies a user, but the personal information we store about the user may be linked to information stored in and obtained from cookies.

We use cookies that allow for better navigation on our website. See our cookies policy.

GMX Brazil has the right to change this privacy policy at any time it deems necessary, without the need for any prior notice, noting that changes, when they occur, will be put into practice immediately by us on our website.

Security measures

GMX Brazil, in order to achieve extreme levels of security, recommends cleaning the browser's history (cache) after user use. In relation to our commitment to comply with the guidelines proposed by the LGPD, international standards when applicable and our purpose of transparency, it adopts procedures for the protection of Personal Data, as follows:

Confidentiality: All members of GMX Brazil are subject to the rule, as well as any contracted third parties who will be obliged to sign the confidentiality term. This case does not apply to executives, since it is an intrinsic rule for the ethical exercise of the profession.

Transparency: In cases of incidents involving the processing of Personal Data, in order to protect the privacy and security of information, we will portray on our website what happened, reaching all users and we will take measures to eliminate any dysfunctions.

Isolation: All access to Personal Data is blocked by functionality in standard mode, as it is exclusively a request for contact for possible business transactions or the power of active interaction with "posts" using our BLOG (always by free will and initiative of the users ). We point out that, although the website entails the privilege of passive agent, we limit access to all communication to GMX executives or trusted collaborators who have a confidentiality agreement.

Incident Reporting: In the event of a security incident, which may or may not entail risks or relevant damage to user data, GMX Brazil will notify the National Data Protection Authority (“ANPD”), which in turn will notify the data subject in reasonable time, containing information about the description and nature of the Personal Data affected. The ANPD may also indicate technical and security measures used to protect data, related risks and measures that have been or will be adopted to reverse or mitigate the effects of the damage. We point out that e-mails sent and/or received only establish communication, therefore, being the sole responsibility of the companies responsible for the e-mail domain platform.

We reserve the right to update this policy at any time, without prior notice, so please check it regularly.