1. Privacy Policy

In order to show transparency and in compliance with the applicable legal obligations, the company Augusto de Oliveira Soares ME (“Terceiro Ato”) complies with the obligation to inform the purpose of the use of the Collected Data by the company and the rights that have the Individuals (PF) Holders of these data.

If you have questions or concerns regarding the processing of Personal Data, please feel free to contact us through the Privacy Channels identified below.

This Policy presents information about the processing of personal data performed by the company Augusto de Oliveira Soares CNPJ [Tax ID] 04.947.671/0001-15 with headquarters at Avenida Paulista 1.079 andar [floor] 7/8 conj. [suite] 71 e 81 CEP [ZIP CODE] 01.311-020 Bela Vista São Paulo SP, in its relationship with the users of these Services (“you”) for any purposes.


2. Objectives of this Policy

Terceiro Ato uses its best efforts to provide adequate protection measures in all its operations. For recognizing the importance of your privacy, we have developed this Policy to inform you of the conditions under which we handle and protect your Personal Data. This Policy also describes your rights and how you can contact us to exercise them or ask us any questions you may have about the protection of your Personal Data.


3. Concepts

ANPD (NATIONAL DATA PROTECTION AUTHORITY): a Brazilian public administration agency, responsible for ensuring, implementing and enforcing compliance with the Brazilian General Data Protection Act throughout the Brazilian territory.

PERSONAL DATA (PD): information related to an identified or identifiable natural person. Personal data includes:

First and last name;
Age (Date of Birth);
Email address, among others

SENSITIVE PERSONAL DATA: according to the Brazilian legislation, sensitive personal data is that which refers to racial or ethnic origin, religious conviction, political opinion, membership of a union or religious, philosophical, or political organization, data concerning health or sex life, genetic or biometric data, when linked to a natural person.

CLIENT: is the individual or legal entity that purchases the services of Terceiro Ato.

COOKIES: These are information files that are stored on the computer or mobile devices by means of the internet browser (browser). These files allow, during a period of time, a website to “remember” the actions and preferences registered on behalf of the user.

COLLECTION: for the purposes of this policy, it is the process of collecting Personal Data.

CONTROLLER: natural or legal person, of public or private law, who is responsible for decisions regarding the processing of personal data.

LGPD: Brazilian General Data Protection Act (Act 13.709/2018).

OPERATOR: natural or legal person, of public or private law, who performs the processing of personal data on behalf of the Controller.

PROCESSING: refers to every operation performed with PDs from the moment of collection.

HOLDER OF PERSONAL DATA/Data Subject (Holder): Individual to whom the personal data that are the subject of processing refer to.

4. Origin of Personal Data

Terceiro Ato collects and processes your Personal Data so that it can carry out its audiovisual production functions. Such Personal Data may be provided: (i) by yourself when providing information when using the Website; (ii) by the company that contracts Terceiro Ato’s services; and (iii) by automatic collection, when browsing the Website.

Personal data provided by the contracting company or by you: The information collected by Terceiro Ato includes:

1. Being the client a natural person, data such as: name and email.
2. Being the client a legal entity: company name, CNPJ [Tax ID], name of the legal representative, full address, email and telephone number.
3. Data of an individual due to contract execution with a contracting company: name, position and images recorded on video (the consent for use of image and personal data is always a responsibility of the contracting company).

Personal Data collected automatically: We collect some information automatically when you visit our Website in order to personalize and enhance your experience. We collect this information using several methods, such as:

Cookies: There are no cookies.

Statistics: The Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to generate statistical reports. These reports tell us, for example, how many users have visited the Website, which pages have been visited, and in what geographic areas users of the Website are located.

The information collected through statistics may include, for example, your IP address, the originating website from which you arrived at our Website, and the type of device you have used. Your IP address is hidden on our systems and will only be used if necessary, to resolve a technical problem, for the Website administration and to obtain an overview of the preferences of our users.

Website traffic information is accessible only to authorized persons. We do not use any of this information to identify visitors and do not share it with third parties who are not directly or indirectly involved in providing service.

Social Networks: You have the option to click on the dedicated social networking icons such as Facebook, Twitter, LinkedIn and YouTube that appear on our Website.

Social networks create a more friendly atmosphere on the Website and help promote it through sharing. Video sharing services enrich the video content on our Website and increase its visibility.

When you click on the icons, we may have access to Personal Data that you have made public and accessible through your profiles on the social networks in question. We do not create or use any separate database on these social networks based on the Personal Data you have posted there, and we do not use these means to process any data relating to your private life.

If you do not want us to have access to your Personal Data posted in the public spaces of your profile or social accounts, you should use the procedures provided by the social networks concerned to limit access to such data.


5. Purposes for which we use Personal Data

The Personal Data that Terceiro Ato collects is used to advertise and provide its services.

Specifically, Terceiro Ato may use your Personal Data for the following purposes:

– to administer, to provide the services, and to fulfill the obligations arising from the services provided by Terceiro Ato;

– to inform you about the latest developments, services, features, content, promotions, news and other relevant events and events of relationship with users

– to inform you about relevant commercial events;

– to personalize and enhance your experience on our Website;

– to offer you our products and services;

– any other purpose that will be reported to you, if applicable, when we collect your data.

Terceiro Ato does not sell and/or trade information that can identify you.


6. Legal Basis for processing Personal Data

Terceiro Ato performs the processing of Personal Data in accordance with the legal bases established by the LGPD and in a manner appropriate and compatible with the purpose of its collection. We process your Personal Data as part of the performance and management of our contractual relationship with you and/or the company contracting our services, in our legitimate interest or that of third parties, provided that the legal requirements to do so are met, in compliance with certain legal or regulatory obligations, or when necessary, for the regular exercise of rights in judicial, administrative or arbitration proceedings.


7. Sharing of Personal Data

We restrict access to your Personal Data only to our duly authorized professionals who need to know such data to process your orders or provide the requested service(s).

We will not disclose your Personal Data to unauthorized third parties. However, we may share your Personal Data with authorized service providers with whom we work as consultants in the areas of technology and information technology; to whom we can turn for the purpose of providing our services. In such cases, we will ensure that your Personal Data will only be processed for purposes that are legitimate, specific, explicit, and reported to you, and will not be further processed in a way incompatible with the stated purpose.

We do not authorize our service providers to use and/or disclose your Personal Data except to the extent necessary to provide the services on our behalf or to comply with legal obligations. Our service providers will only use your Personal Data in accordance with the instructions issued by Terceiro Ato and in accordance with the purposes mentioned in this Policy.

In addition, we may share Personal Data about you when we believe in good faith that we have an obligation to: (i) comply with the law, regulation or court order; (ii) respond to requests for information made by a regulatory agency, law enforcement and other public authorities, including in cases concerning national security; or (iii) enforce and/or protect Terceiro Ato property or rights, including to investigate fraud and help prevent security threats, including information security, or other criminal or malicious activity.


8. Storage of your Personal Data

We will store your Personal Data in our databases in a secure environment, ensuring secrecy and confidentiality, only for the time necessary to fulfill the purposes for which they were collected, subject to any legal deadlines and the need to defend Terceiro Ato in litigation. Upon expiration of the legal time limit and legal necessity, your Personal Data will be deleted using secure disposal methods.

The Personal Data obtained may be stored in a third-party company hired for this purpose, whether allocated in Brazil or abroad, and may also be stored by means of cloud computing technology and/or others that may arise in the future, always aiming to improve and enhance their activities, respecting the levels of security and best market practices.


9. Sensitive Personal Data

If it is strictly necessary to collect such data to achieve the purpose for which the processing is carried out, we will do so in accordance with local legal requirements for the protection of Personal Data and on the legal basis provided in the LGPD or your prior specific and outstanding consent, for specific purposes under the conditions described in this Policy.


10. Processing of Personal Data of Children and Adolescents

If it is strictly necessary to collect such data to achieve the purpose for which the processing is carried out, we will do so in accordance with the local legal requirements for the protection of Personal Data and with the consent of a parent or legal guardian.


11. International Transfer of Personal Data

Your Personal Data may be transferred to recipients located outside Brazil who are authorized to perform services on our behalf. Personal Data protection laws vary by country, but in the event of an international transfer to recipients located in other countries, we will take the necessary measures to ensure that adequate guarantees exist for the protection of your Personal Data in accordance with the LGPD and in compliance with the protections described in this Policy.


12. Exercise of your rights under the LGPD

The Holder of Personal Data has the following rights to the controllers of his/her personal data:


– Confirm the existence of Processing: the Holder of Personal Data may request to Terceiro Ato a confirmation that their Personal Data is being processed;

– Access to Personal Data: the Holder may ask to Terceiro Ato which Personal Data about him/her are stored;

– Correction of Personal Data: the Holder may request the correction or completion of incomplete, inaccurate or outdated Personal Data. To do so, it is necessary to submit some legitimate evidence that proves the correct form of the Personal Data;

– Anonymization, Blocking or Deletion: if the Holder wishes his/her Personal Data to be deleted, he/she may contact Terceiro Ato. If the Personal Data does not impact the provision of our services, we will proceed with its deletion; however, if the information is essential to our operation, we may Anonymize the data so that it is not possible to identify the Holder. In addition, the Holder may also request the anonymization of his/her Personal Data, in which case we will assess the possibility of doing so without having an impact on the provision of our services to the Holder. Finally, the holder may request the blocking, i.e., the temporary suspension of any processing operation. In this case, we emphasize that the supply of services by Terceiro Ato and the contractual relationship with the data holder may be harmed, given the impossibility of processing the data;

– Information on Sharing of Personal Data: whenever there is no legal impediment, the Holder may request Terceiro Ato to inform with which third parties and why it shares his/her Personal Data.

– Revocation: if the Holder has given consent for the processing of his/her Personal Data, he/she may request revocation as long as it does not make it impossible to use the functionalities of the service offered, unless the service is terminated;

– Portability: right to request a copy of your Personal Data that we have and the right to transmit such copy to third parties.


13. Where to look for additional information

 If you have any problems, questions, complaints or requests regarding the processing of Personal Data, you can contact us at dpo@terceiroato.com or by letter to the following address: Avenida Paulista 1.079 andar [floor] 7/8 conj. [suite] 71 and 81 CEP [ZIP CODE] 01.311-020 Bela Vista São Paulo SP

14. Changes to this Privacy Policy

This Privacy Policy may change over time. This Privacy Policy was last updated on 01/15/2021.