1.    INTRODUCTION

Law nº 13.709/2018 (General Data Protection Law or, simply, “LGPD”) regulates the processing of personal data in order to protect the fundamental rights of freedom and privacy.
The law places citizens in the position of holder of their data and, in this light, establishes important and mandatory guidelines for the collection, processing, storage and deletion of personal data, both in digital and physical media.
Through this Privacy and Data Protection Policy Manual, the collaborators of the Raposa Extrajudicial Service will become aware of the main guidelines, policies, principles, standards and commitments related to the privacy and security of the information provided by users. All with the aim of clarifying the types of data processed, the purpose of this treatment and how the user will be able to manage their personal data.
This Manual complies with Law No. 13,709/2018, with Law No. 12,965/2014 (Marco Civil da Internet) and with the Code of Rules of the General Court of Justice of the State of Maranhão. Its content will be revised whenever necessary to adapt to legal or administrative norms or, also, due to circumstantial changes, such as technological innovations and good practices, and this Office undertakes to maintain an updated version of this document publicly accessible on the website and in the Registry. .
If the user has questions about the treatment of their data, we recommend contacting our holder, through the electronic address tabeliao@cartorioraposama.com.
Ensuring legal certainty is one of our most important values and protecting your personal data is a priority for us.

2.    DEFINITIONS

In order to facilitate your reading and familiarization with the terms used in the LGPD, used in this Manual or even found in privacy policies in general, we present some useful definitions on the subject:
 
•    “Personal Data”: all information related to the identified or identifiable natural person, that is, any information that identifies or can identify a person, such as names , document numbers, addresses, etc.
•    “Sensitive Personal Data”: personal data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical nature or political, data relating to health or sex life, genetic or biometric data, when linked to a natural person.
•    “Personal Data Subject” (“Holder”, “User”, “You”): natural person to whom the personal data that are treatment object; holder of personal data accessing the Notary's platform.
•    “Platform”: the website www.cartorioraposama.com owned by this Notary.
•    “Processing of Personal Data” (“Processing”): It is all the operation carried out with personal data, such as collection, production, reception, classification , use, access, reproduction, transmission, distribution, processing, archiving, storage, disposal, evaluation, control of information, communication, transfer, dissemination or extraction.
•    “Controller”: natural or legal person, governed by public or private law, who is competent to make decisions regarding the processing of personal data.
•    “Operator”: natural or legal person, governed by public or private law, who processes personal data on behalf of the controller.
•    “National Data Protection Authority” (“ANPD”): public administration body responsible for ensuring, implementing and monitoring compliance with the LGPD.
•    “In charge” or “DPO” (Data Protection Officer): person appointed by the controller and operator to act as a communication channel between the controller, the holders of data and the National Data Protection Authority.
•    “Consent”: free, informed and unequivocal expression by which the holder agrees to the processing of their personal data for a specific purpose.
•    “Elimination”: deletion of data or a set of data stored in the database, regardless of the procedure used.
•    “Third Party”: natural or legal person, public authority, agency or body other than the data subject, controller, operator and persons who, under the direct authority of the controller or operator, are authorized to process personal data.
•    “Data Security”: technical and administrative measures capable of protecting the security of data in its processing.
•    “Cookies”: files saved on your computer, tablet or phone when you visit a website. We use the necessary cookies to make the website work in the best possible way and thus offer quality services. Some cookies are classified as necessary and enable core functionality such as security, network management and accessibility. These cookies may be collected and stored as soon as you start browsing or when you use a feature that requires them.
 
•    “Pixels': pieces of Java Script code, installed in applications, websites or in the body of an email, for the purpose of tracking and collect information about the activities of users, allowing the identification of their patterns of access, navigation, interest and purchases of products, to optimize the targeting of content.
•    “Web beacon”: technique that allows mapping who is visiting a given web page, identifying user behavior with different websites or web servers.
•    “Analytics tools”: tools that collect information about how users visit the website or other applications, which pages they visit and when they visit such pages, as well as other sites that have been visited before, among others.

3.    APPLICATION ASSUMPTIONS

The data collected by the Notary, whether registered on this Platform or those that come to compose its physical or electronic database through face-to-face service, refer to the exercise of its attributions regarding the protest of titles and documents, civil registration of legal entities and registration of titles and documents. Therefore, they are used to enable the performance of official acts requested by users, through compliance with the legal and regulatory provisions relating to them.

The user who decides to provide his personal data, necessary for the practice of any service performed by the Notary, declares to be aware and agree with the terms described in this Manual. The agreement with this Privacy Policy is essential for the use of the site and the services offered by Serventia Extrajudicial da Raposa/MA.

4.    LEGAL BASES FOR TREATMENT

The processing of personal data by the Notary is carried out under specific and appropriate legal bases for each of the attributions mentioned in the previous topic. See below the main applicable standards:

•    Law nº 8.935/94
•    Law nº 9.492/97
•    Law nº 6.015/73
•    Code of Rules of the General Court of Justice of the State of Maranhão
•    Provimento nº 61/2017 do CNJ
•    Provimento nº 74/2018 do CNJ
•    Provimento nº 87/2019 do CNJ
•    Provimento nº 88/2019 do CNJ

With reference to the authorization requirements provided for in the LGPD, the grounds for processing can be listed as follows:
 
a)     based on the user's consent (art. 7, item I of the LGPD);

b)    for compliance with legal or regulatory obligations (as mentioned above), in particular BACEN resolutions regarding banking transaction data (art. 7, item II of the LGPD);

c)    when necessary for the performance of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (art. 7 , item V of the LGPD);

d)    when necessary to meet the legitimate interests of the controller or third parties, except in the event that the holder's fundamental rights and freedoms that require the protection of personal data prevail (art. 7, item IX of the LGPD); and

e)     for credit protection (art. 7, item X of the LGPD), in accordance with Law No. 9,492/97 and Provision No. 87/ 2019 of the CNJ.

5.     TREATMENT PURPOSES

The processing of personal data has the purpose of providing notary and registry services or, even, the exercise of the right, under the terms of current legislation.

The data collection also aims to act effectively and provide improvements in the user experience with the services offered on the website.

Most of this data is explicitly requested through physical or electronic forms. This data will be used exclusively to fulfill the requests sent to the services provided by these tools, in order to expedite and fulfill their purpose.

Statistical analyzes will be carried out to interpret the usage patterns of the site and services  disponiv́ eis,  a _cc781905-5cde-3194-bb3b-136bad5_5cc-59d_fim 0 bb3b-136bad5cf58d_de  melhorar,  de  forma  contiń  ua,  a  provision  dos _cc781905-5cde-3193-bb3b-5b.  The resulting statistical information will not be subject to any personal identification of users.

If there are changes in the purpose for the processing of personal data, which are not compatible with the original consent, the holder will be informed in advance, guaranteeing the right to revoke consent, if he disagrees with the changes.

See, in more detail, the purposes for which personal data will be processed by the Notary:

•     Qualification of the parties in the acts relating to the registration of titles and documents, the registration of legal entities and the protest of titles and documents
 
•    Submission of extrajudicial notifications
•    Sending subpoenas of protests
•    Receipt and submission of electronic documents for registration and protest purposes
•    Requesting acts and sending certificates related to their attributions
•    Protocol consultation for online monitoring of services on the Notary's website
•    Query whether or not there is a protest
•     Consultation on the current situation of the title
•    Consultation of electronic public notice
•     Electronic seals authenticity inquiry
•    Certificate authenticity consultation
•    Scheduling for face-to-face service
•    Verification of authenticity of documents and digital signatures received, as a fraud prevention measure
•    Record of financial and banking transactions related to services requested such as credit card, bank slip and means of payment in general
•    Issuance of invoices to Raposa City Hall
•    Issuance and sending of digital seal on the website of the Court of Justice of Maranhão
•    Issuance of declaration of real estate operations (DOI) to the Internal Revenue Service;
•    Issuance of a declaration of suspicious operations to SISCOAF, pursuant to CNJ Provision No. 88/2019
•    Sending of data to Notaries Maranhão, Censec, CRC, SIRC, SERP, SINTER and the Federal Revenue
•    Sending information to public bodies and shared electronic service centers that result from legal or regulatory provisions, such as information on securities to the IEPTB
•    Manage and respond to requests made by users, in accordance with the rights of data subjects, provided for in art. 18 and following of the LGPD

To meet the legitimate interests of the Notary, personal data will be processed to:

•    Registration in the Ombudsman system by e-mail, telephone, Whatsapp or correspondence intended for direct service to the public, for requests for information, complaints, compliments, suggestions , among others
•    Analysis of Platform statistics via Google Analytics, in order to monitor access to the site without collecting data that identify users
•    Communication to recipients about the need to pay costs and fees to cancel the protest

Always with the prior and express consent of the respective holder, personal data will be processed by the Notary to:

•    Registration on the Platform
•     Personal identification and/or authentication for accessing online services
•    Eventual user login and password recovery
•    Save search history
•     Communications or messages by phone, applications or electronic address regarding the progress, pending issues or completion of the services requested to the Notary through the website, by electronic means or in attendance presential
 
6.    TYPES OF DATA COLLECTED

The processing of personal data by the Notary of Raposa is carried out under specific, adequate, relevant and limited legal bases for the purposes mentioned in the previous topic.

During the use of this site or in person service or by electronic means, the Notary may collect data and identification information to carry out registration in its own form and for the purpose for which it is intended.

The information and data collected can be related and exemplified as follows:

•    Information for the practice of extrajudicial services: full name; CPF or CNPJ; nationality; marital status, existence of a stable union and affiliation; profession; full address; electronic address (email).
•    Contact Information: includes any type of contact data such as name, email address, phone numbers, messaging application numbers.
•    Login and password information: includes information to identify and authenticate in services provided by the Notary.
•    Technical Information: includes information about your computing equipment or mobile devices, such as a record of the IP address used to connect your computer or device to the internet, including your geographic location , operating system and web browser type.
•     Demographic information: includes information about demographic data such as date of birth, age or age group, gender, geographic location.
•    Informações  sobre  navegação  no _cc781905-5cde- 3194-bb3b-136bad5cf58d_site  e  servicos: incluem  informaçoes̃   _cc781905-5cde-3194-bb3b -136bad5cf58d_about  as
pages and content of our website and other statistical information about your interactions, such as response times to content and duration of access, service availability, etc.
•    Third Party Social Network Information: Includes information that is shared or made public whenever you interact with us through a third party social network. Examples: account name, full name, email address, gender, date of birth, current city, and profile picture.
•    Financial and payment information: any of the services provided on our website to fulfill a payment request by collecting financial and payment data for your processing in accordance with applicable laws, regulations and security standards for the provision of the service.

 

7.    SHARING INFORMATION AND PERSONAL DATA

Publicity is part of the nature and purposes of notary and registry services (Article 1 of Law No. 8,935/94), which includes the duty to issue certificates (Law No. 8,935/94, Law No. 6,015/73, Law No. 9,492/97 and other applicable rules).
 
In addition to this specificity, personal information and data can be shared in the following cases:

•     internally, with authorized service personnel;
•     performance of services or acts determined by law or specific regulations, such as: issuance of certificates; sending electronic seal; information to COAF or the Internal Revenue Service; issuance of bank slip according to BACEN;
•    compliance with requests from judicial and administrative authorities;
•    integration with registries and shared electronic service centers of notary and registry institutes, related to services (eg IEPTB);
•     in any legal proceedings, with law firms;
•     in the investigation of possible crimes, with the competent authorities;
•     in contracting services (eg data hosting).

With regard to sharing, we ensure that: (i) no personal data will be transferred, free of charge or commercially, to marketing companies; (ii) we demand from our service providers the observance of rules compatible with this policy and with the legislation in force in relation to the protection of personal data.

8.    USER RIGHTS

Know your rights here:

•    Request information on whether your data is processed by the Notary, and how this is done.
•    Request access and confirmation of personal information we hold. For this, we may need to confirm your identity, after which we will provide you with a report on the information in our possession.
•    Revoke, modify or deny your consent at any time, with the exception of data processed through legal, regulatory or legitimate interest, provided that, after notification , we will no longer process your personal information for the purposes for which it was intended.
•        Solicitar a informação sobre eventual possibilidade de não dar o seu consentimento e sobre the effects and possible negative consequences in each case.
•     Request the correction of incomplete or inaccurate information about you that is in our database.
•     Request the anonymization, blocking or deletion of data that it deems unnecessary for the purpose being used, or that it considers excessive or treated in violation of the GDPR .
•     Request that your information be deleted from our files and systems when there is no reason to keep it.
•     Request information regarding the possible sharing of your data with public or private institutions.
•     Request data portability to another service or product provider.
 
•    Request the review of decisions made solely on the basis of automated processing of personal data that affect your interests, including decisions aimed at defining your personal, professional profile , consumption and credit or aspects of your personality.
•    Request deletion from our communication lists to stop receiving our messages and e-mail.

Important notes:

(i)     In meeting the requests listed above, we may occasionally ask for some additional information to prove your identity, in order to guarantee security, privacy and prevent frauds.
(ii)     When applicable, and even if you choose to delete your data from our database, the Notary may retain some or all of your personal data for additional periods or for other periods defined and based on legal bases that justify the retention of data, aiming at the fulfillment of legal or regulatory obligations, for the regular exercise of rights or audit purposes of various natures.
(iii)     The person in charge will contact you within 48 working hours, and although some requests may not be answered immediately, they will be answered within reasonable and in accordance with applicable law.

9.    DATA SECURITY

In compliance with the principles of the LGPD and with good information security and personal data protection practices, the Notary ensures that the personal data collected are treated in a complete and secure manner, in accordance with technical and administrative security standards and norms. information, confidentiality and integrity, for the time necessary to carry out the purposes for which they were collected or to comply with applicable legal requirements.

The Notary has internal control over access to your information through login access controls with tracking, all procedures performed by our employees are documented and we provide technical and behavioral training with our team on the proper and safe use of available tools.

The personal data processed by the Notary is considered confidential and will only be accessed by authorized and qualified persons to give them the appropriate treatment, according to adequate security measures to protect against unauthorized access, alteration, disclosure or destruction of personal data collected and stored.

As foreseen in the legislation, the existing security measures consider the nature of the data and treatment, the risks involved, the existing technology and its availability. However, despite the efforts, it is necessary to keep in mind that no system is completely safe.
 
It is important to note that this site may provide access to links and frames from other sites whose contents and privacy policies are not the responsibility of the Notary, so we always recommend consulting the respective privacy policies when being redirected to external sites or third-party services. made available through this platform.

Access to the services of this site by the registered user is exclusive through the login environment, which is the password for individual use and the user's responsibility. Therefore, we reinforce the care not to pass them on or share them with third parties, thus helping us to maintain a safe environment for everyone.

If you identify, become aware of or suspect something that compromises or may compromise the security of your data, contact the person in charge through the channels described in item 12.

10.    COOKIES AND MONITORING TECHNOLOGIES

Some tracking technologies, such as cookies, pixels, web beacon and
analytics may be present on the site and on devices.

The information collected through such technologies is used to perform application performance metrics, identify usage problems, capture user behavior in general and collect content impression data.

11.    DATA SECURITY INCIDENT

In the event of a security incident involving personal data, the technical and security measures will be taken in accordance with the nature and extent of the risks involved and the communications containing the description of the risks, holders involved and technical and security measures adopted for the handling of the incident will be carried out in accordance with applicable legislation and standards.

12.    CONTACT WITH THE PERSON

If you believe that your personal data has been used in a way that is incompatible with this Privacy Policy or with your choices as a data subject, or if you have any questions, comments or suggestions related to this Policy, please contact us through the person in charge. (Data Protection Officer - DPO), which is available at the following contact addresses:

•    DPO: Edson Henrique Teixeira Filho
 
•    Address: Av. do Araçagy, no. 03, rooms 13 to 15, Centro Comercial Pirâmide, Raposa/MA, CEP: 65.138-000

•    E-mail (email address): lgpd@cartorioraposama.com

13.    UPDATES AND FINAL PROVISIONS

This Privacy and Data Protection Policy Manual may change, especially when new recommendations are published by the ANPD or legal or administrative determinations by Organs competent bodies, as they may issue new guidelines or guidelines on the topics and procedures described. in this document.

The Notary may also update this Policy whenever it incorporates new features and services, in order to provide improvements in the users' experience.

Updates will be made by publishing the new version and identifying the date of the last update, from which they will be immediately valid and applicable.

Significant changes will be communicated through the channels provided by the user, but we also recommend that you revisit this document from time to time to be always up to date on specific changes.

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Last update date: Raposa/MA, August 10, 2022 – Version 00.