Privacy Policy

Updated on January 14, 2025.

Privacy Statement

3L ASSESSORIA EMPRESARIAL LTDA – ME (“ASAP”), a CORPSERVICES GROUP company, understands the importance of knowing and being secure about the use of the personal data it holds. Therefore, we are committed to clarifying and explaining our Privacy Notice. We recognize the need for protection and proper management of personal information collected on our website, as well as information shared with us by our clients. This Privacy Notice will help you understand what types of information we may collect, how this information may be used, with whom the information may be shared, and what rights data subjects have regarding the protection of their personal data.

2. What personal information do we collect? The personal information we obtain may be collected in the following ways: Site:

Personal information is collected when a user interacts with our website through a contact form. This personal information includes first name, last name, email, and phone number. Collection of basic data is only necessary when the user requests a response. All personal information is collected fairly and non-invasively, with your voluntary consent.

The personal information collected is accessible only to those who need to know it to perform relevant activities, respecting the purpose for which it was provided.

Customer service channels: Users can contact “ASAP” by phone, email, chatbot tool, and in person at our offices. Personal data is collected to identify the user and to fulfill their request. This may include, among other things, full name, email, and phone number. In addition to these, we collect any personal data that is voluntarily provided by the user.

Cookies:Personal data may be collected through cookies. For more information, please see our Cookie Policy.

Data related to the provision of services: For the proper provision of our services and in compliance with legal and contractual obligations, we process personal data, which includes: Name, identification documents, telephone number, email address, as well as information voluntarily disclosed by the data subject.

Job applicants: Personal information from job applicants is collected through email submissions from interested candidates. The personal data collected includes, among other things, full name, phone number, email address, field of study, city of interest, desired position, and other professional information completed or submitted via email in the resume sent by the applicant.

Employees:Regarding the personal data collected from our employees, this data is necessary for employee registration, in compliance with labor laws and the execution of the employment contract.

Monitoring wired and Wi-Fi networks: We collect personal data from all users of the wired and Wi-Fi network provided by “ASAP”, based on our legitimate interests, for the purposes of internal and/or external monitoring of the artificial environment we provide. Exceptionally, “ASAP” will process sensitive personal data, in which case the provisions of the LGPD (Brazilian General Data Protection Law) will be duly observed.

3. Social Media

ASAP also uses social media to communicate and interact with its clients and consumers through third-party websites such as Instagram and LinkedIn. These third-party websites are internet-based technology that is not operated or controlled by ASAP. By interacting with, sharing, or “Liking” ASAP’s page on Instagram, LinkedIn, or other social media, you may disclose certain personal information to ASAP or third parties. We use “social buttons” to allow our users to share or bookmark web pages. These are buttons from third-party social media sites that may record information about your online activities, including on this website. Please review the respective Terms of Use and Privacy Notices of these platforms to understand exactly how they use your information, and to opt out of receiving or deleting such information. The amount of personal information visible will depend on your own privacy settings on Instagram, LinkedIn, and other social media.

4. Purposes and Legal Bases The purposes and legal bases for data processing by “ASAP” are listed below:

We only act based 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 data subjects.

5. Regarding the sharing and transfer of information

ASAP does not, as a matter of practice, disclose information that could identify the user and never shares, sells, or rents this personal data to third parties. This data is for the exclusive internal use of the group’s companies, to achieve the purposes expressed in the previous item. The data may only be shared with third parties under the following conditions:

• By court order or request from government oversight bodies;
• Data transferred to public bodies to comply with current legislation, for example personal data contained in electronic invoices and their respective XML files, or data from our employees necessary for the payment of INSS (Brazilian Social Security) or FGTS (Brazilian Severance Indemnity Fund);
• Data transferred to financial institutions to enable payment options for our customers, or for the payment of salaries to our employees and service providers;
• Data shared with the controlling company “CORPSERVICES GROUP” in order to enable the proper provision of services;
• Data shared with partner companies, operators, and service providers that participate, directly or indirectly, in the development of ASAP’s commercial activities, such as: collections, payment processing, customer service, email sending, advertising and marketing, security and performance monitoring, order and transaction processing and fulfillment, consumer registration information verification services, research, data storage and processing;
• Data transferred for the purpose of executing the contract, as well as for the protection of ASAP’s interests in any type of dispute, including legal proceedings;
• In the event of corporate transactions such as mergers, acquisitions, transformations, spin-offs, or a partial or total sale of assets, we may share, disclose, or transfer all data of the data subjects to the successor organization.

Some of the service providers mentioned above may be located abroad, and in that case, “ASAP” adopts additional safeguards to guarantee an adequate level of protection of personal data, in accordance with the provisions of the relevant Brazilian legislation. In operations involving the sharing of your personal data with Data Processors, we will require that they be processed in accordance with our instructions, in our capacity as the Controller of this information, including with respect to other processing agents involved in the data processing chain, including Sub-processors.

6. Information Security

To ensure that your personal information is secure, we communicate our privacy and security guidelines to ASAP employees and business partners and strictly adhere to privacy precautions within the group companies. We are committed to protecting your personal information, and that entrusted to us by our clients, through physical, technical, and organizational measures aimed at reducing the risks of loss, misuse, unauthorized access, disclosure, and improper alteration of this data.

7. Rights of Data Subjects

Data subjects have certain rights regarding their personal data and can exercise them by clicking here to access the Data Request Form (DSAR) or by email: dpo@corpservices.com.br. The rights of data subjects include:

• Confirmation of the existence of personal data processing;
• Access to personal data, in accordance with applicable legislation;
• Correction of incomplete, inaccurate, or outdated personal data;
• Portability of personal data;
• Exclusion of personal data when it is processed based on the consent of the data subject or when the data is unnecessary, excessive, or processed in violation of applicable law;
• Request for information regarding the shared use of personal data;
• Revocation of consent, where applicable.

ASAP will always evaluate the best way to fulfill your request to exercise any of your rights. However, ASAP may fail to fulfill your request, in whole or in part, in specific situations protected by law, such as, for example, to comply with a legal obligation or a contract it has with you. We emphasize the importance of keeping your personal data accurate and up-to-date. To that end, please keep ASAP informed if your personal data changes or becomes incorrect. For security reasons, for requests made via email to dpo@corpservices.com.br, the request will only be fulfilled when we are certain of the user’s identity.

Therefore, we may request additional data or information to confirm the identity and authenticity of the data subject. This data and information will be protected during the storage period and deleted after the legal deadline for the eventual regular exercise of rights. In cases where “ASAP” is a Personal Data Processor, requests will be forwarded to the Controller for evaluation and decision on the measures to be taken.

8. End of Treatment

This Privacy Notice applies to the aforementioned circumstances for the entire period during which “ASAP” stores personal data. We store and maintain your information: (a) for the time required by law; (b) until the termination of the processing of personal data, as mentioned below; or (c) for the time necessary to protect the rights of “ASAP”. Thus, we will process your data, for example, during the applicable limitation periods or as long as necessary to comply with a legal or regulatory obligation.

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 ceases to be necessary or relevant to the achievement of such purpose; (b) when the Data Subject requests the deletion of their data; (c) when there is a legal determination to that effect; and (d) when the termination of the processing is determined by the Controller. In cases of termination of the processing of personal data, except for the cases established by applicable legislation or by this Privacy Notice, the personal data will be deleted.

9. Data Protection Officer (DPO)

ASAP provides below the contact details of the Data Protection Officer (DPO), who is responsible for handling any and all requests from data subjects or the National Authority related to personal data. For any questions, requests or complaints regarding the processing of personal data, please contact our Data Protection Officer:

DPO EXPERT – (www.dpoexpert.com.br[RP9]) Responsible: Rafael Susskind

Substitute Responsible: Renata Adeli Franhan Parizotto Contact: dpo@corpservices.com.br

If, despite our commitment and efforts to protect your data, you believe that your data protection rights have not been met, please contact our DPO. Furthermore, you have the right, at any time, to file a complaint directly with the National Data Protection Authority if you believe that your rights regarding your personal data have been infringed.

10. Changes to the Privacy Notice

Although our Privacy Notice has been presented in a clear, concise, and objective manner, please do not hesitate to consult the “ASAP” Data Protection Officer (DPO) if you have any questions about this important document or about the personal data processing activities we carry out. “ASAP” 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 process personal data, you will be informed so you can check if you wish to continue using our services.